3519 

OK-302 (Rev 8-19-94) 

- 1 - 

OFFICE OF THE INDEPENDENT COUNSEL 

Dale elf tranrcnpaon 2/4/98 

-- 

THOMAS SCHICK, Executive Vice President, Corpcrate 

Affairs and Communications, AMERICAN EXPRESS, INC.(AE) was made 

available for interview by AE Corporate attorney, MARK BELNICK, 

at the AE Financial Center Tower, 200 Vesey Street, New York, NY. 

BELNICK and his associate JOYCE SZUYUN HUANG of the law firm 

PAUL, WEISS, RIFKIND, WHARTON and GARRISON, 1285 Avenue of the 

Americas, New York City, NY were present during the interview. 

All persons present were advised of the purpose of the interview 

and the official and personal identity of Investigator - 

and FBI Special Agent - SCHICK thereafter provided the 

following information. 

SCHICK has been employed with AE in his present 

position for the past 5 years and prior to that was employed by 

LEYMAN BROTHERS for 9 years. 

SCHICK first heard of MONICA LEWINSKY sometime before 

the 16th of December 1997 when he received her resume from URSULA 

FAIRBAIRN, Executive Vice President for Human Resources and 

Quality for AE. At the time he received the resume from 

FAIRBAIRN, she indicated to him that the resume came from VERNON 

JORDAN and that SCHICK could expect a call from LEWINSKY because 

she had told LEWINSKY on the phone that SCHICK is the appropriate 

person to talk to within AE. 

SCHICK informed his secretary GWYNNzPHILBROOK that a 

person named MONICA LEWINSKY would be calling and that an 

interview needed to be scheduled. 

On December 16, 1997 PHILBROOK received a telephone 

call from LEWINSKY and recorded the time of the call as 12:OO 

noon and wrote the following messag.e from LEWINSKY. 

"Spoke w/Ursie, uf suggested she call you: 

she will be in DC next week-- would like to meet 

with you when convenient" 

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

SA 

by CI Dare dmati 2/4/98 

- 
3520 

29D-LR-35063 

Conrlnuaiton OiOIC-302 of Thomas Schick .on li29/'98 .pagc 

SCHiCK indicated that PHILBROOK was certainly aware 

that his schedule for the next week required him to be in 

Washington, D. C. and she probably recontacted LEWINSKY and set 

up the appointment for 1l:OOam on December 23, 1997. SCHICK does 

not recall talking with LEWINSKY prior to the interview in 

Washington. 

The interview took place in the AE Governmental Affairs 

Office located at 801 Pennsylvania Ave. NW, Washicgton, D. C. as 

scheduled. The Senior Vice President in charge of Governmental 

Affairs is TIMOTHY DAVIS and he is a former employee of VERNON 

JORDAN's and the AKIN GUMP law firm. DAVIS was unaware of the 

scheduled interview, had never met LEWINSKY and had not been 

contacted by JORDAN concerning LEWINSKY. 

SCHICK conducted the interview alone with LEWINSKY and 

the interview lasted approximately 45 minutes. SCHICK indicated 

that he had the resume with him and focused on LEWINSKY's 

education and her work experience at the Department of Defense. 

LEWINSKY talked very little about the WHITE HOUSE except on one 

occasion when asked about her work experience there. SCHICK did 

not ask about reasons for leaving any of her previous employments 

but does recall that LEWINSKY mentioned that she left the 

Pentagon job so that she could move to New York and work in the 

private sector. LEWINSKY mentioned that JORDAN was helping her 

find employment without giving any indication-of why he was 

helping. She also indicated that her current employer would give 

her "high marks". 

SCHICK recalls that he decided early in the interview 

that AE was not the kind of company suited for LEWINSKY and told 

her that she ought to be applying at companies such as HILLKNOWELTON which was one of the largest Public Relations firm in 

the world. SCHICK offered to contact his friend at HILLKNOWELTON. LEWINSKY inquired who he was going to contact at that 

company and SCHICK told her it was the CEO, HOW-D PASTER. 

LEWINSKY observed that was interesting because JORDAN was also 

intending to contact him. SCHICK concluded the interview and 

described it as being "unmemorable". LEWINSKY seemed to be very 
3521 

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

29D-LR-35063 

Conunuation of OK-302 of Thomas Schick .On J-/29/98 .pagc 3 

lacking in experience and-was not particularly impressive. 

SCHICK recalls that after the holidays, probably during 

the first week in January of 1998, he telephoned HOWARD PASTER 

and mentioned the names of two prospective employees to him, one 

of them was LEWINSKY's. PASTER indicated that it might be that 

JORDAN had tried to contact him about LEWINSKY, however he has 

only talked to KEN BACON about her. PASTER told him that BACON 

had called recommending LEWINSKY for employment during the last 

several days. 

SCHICK has had no contact with JORDAN from before 

JORDAN contacted FAIRBAIRN up until the controversy was printed 

in the newspaper. One or two days after the newspapers first 

printed details about the President and LEWINSKY, SCHICK 

remembers that he was in Washington and decided to call JORDAN to 

tell him about the media inquiries that AE was receiving. SCHICK 

recalls that before he could finish his statement, JORDAN 

cautioned him to 1) tell the truth and 2) he would be making his 

own statement to the press about the situation. This was a very 

short conversation and occured in the late morning. 

SCHICK stated that he felt absolutely no pressure to 

hire LEWINSKY and never talked to JORDAN at any time during this 

process. 

SCHICK is described as follows from,observation and 

interview: 

NAME: 

SEX: 

RACE: 

DOB: 

SSAN: 

RESIDENCE: 

TELEPHONE: 

EMPLOYMENT: 

TITLE: 

Thomas Schick 

Male 

Caucasian 

l/31/47 

-- 

American Express, Inc. 

Executive Vice President, Corporate 

Affairs & Communications 
3522 

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

29D-LR-35063 

Continuation of OIC-302 of Thomas Schick .On J-/29/98 , Page 4 

TELEPHONE: d-b 
3523 

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

OFFICE OF THE INDEPENDENT COUNSEL 

Dare of nanxnption 2/10/98 

DEBRA ANNE SCHIFF, white, female, date of birth 

_-jr Social Security Account Number 4-4, 

place of birth Hollywood, California, home address f-y) 

----8‘-rr 

pager extension 

cellular phone number _, White House 

m, work telephone number 4-w was 

apprised of the official identity of the interviewing Agents and 

the nature of the interview. SCHIFF was interviewed at suite. 

300, Thomas Jefferson Street, Northwest, Washington, DC, the 

offices of CARY M. FELDMAN, SCHIFF's attorney. FELDMAN was 

present during the interview. SCHIFF provided the following 

information: 

SCHIFF worked for Air Advantage during the 1992 

Presidential campaign as a broker. From March of 1992 until 

November of 1992, SCHIFF logged more than three million miles in 

air travel. SCHIFF flew twenty to twenty-five days out of each 

month during the campaign. 

SCHIFF advised that she first met MONICA LEWINSKY 

sometime in 1995, prior to LEWINSKY working at the White House. 

SCHIFF attended two parties where LEWINSKY's mother and aunt were 

present. One was at LEWINSKY's aunt's house in Warrenton, 

Virginia and the other was at a restaurant. SCHIFF advised that 

WALTER KAYE, a gentleman SCHIFF first met at the White House in 

1994 and befriended immediately, invited SCHIFF to the parties. 

SCHIFF believes that MONICA LEWI_NSKY may have been present at one 

of these parties. SCHIFF described LEWINSKY's family as friendly 

but aggressive. LEWINSKY's mother may have sa%d something to 

SCHIFF about MONICA LEWINSKY wanting to work at the White House. 

SCHIFF had nothing to do with LEWINSKY obtaining her 

White House internship. SCHIFF has assisted one person, COURTNEY 

MONIE, SCHIFF's minister's daughter, obtain a White House 

internship..“ 

SCHIFF advised she thought LEWINSKY was too aggressive 

as an intern. SCHIFF advised that most interns were shy and 

reserved. LEWINSKY dressed provocatively, wearing low-cut 

dresses and very short skirts. SCHIFF saw LEWINSKY with 

President WILLIAM JEFFERSON CLINTON on one occasion. SCHIFF 

Investiganon on 2/10/98 It Washington, DC Fide # 29D-OIC-LR-35063 

SA:-_L ’ 

Date dictated 2/10/98 
3524 

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

29D-OIC-LR-35063 

Continuation of OK-302 of DEBRA SCHIFF ,On z/10/98 . Page 2 
3525 

OIC-302a (Rev. 8-19-91’1 

29D-OIC-LR-35063 

Continuanon of OK-302 of DEBRA SCHIFF ,On 2/10/98 .hge 2 

in her area and it is used by most people in the West Wing. 

SCHIFF does not know if JOHN PODESTA ever used the fax machine in 

SCHIFF's area. 

SCHIFF was shown document "828-DC-00000012," a faxed 

copy of LEWINSKY's resume. This document is attached to this FD302 and incorporated by reference. SCHIFF advised she has never 

seen the resume before in her life. SCHIFF also advised that she 

was mad that someone had faxed the resume from the fax machine in 

her area. 

SCHIFF advised that BETTY CURRIE is her closest friend 

at the White House. SCHIFF is also friends with HEATHER 

MARABOUT, HEATHER NEW and STEPHANIE STREET. 

SCHIFF advised she knows VERNON JORDAN, but is not a 

social acquaintance. 

_- 
3526 

10/21/S? TlE 15:OS F.u; 202 lS6 1210 DE31 SCilXFF @OC:: 

Education: 

Lewis and Clark Collage Portland, Ore& 

Iwbeiot of scicncc in Aycho&gy May 1995 

Department of Defense The Pentsgon Waalhgton, D.C. 

~~Assiatonttol)lc~irLontSea~ofLkfwLdrzfwlpublicqffoirt 

April 1996 - prerent 

Serve 1w pksipal assistant to the Amintant kxretaxy ofDefame @SD) for Public Affaira in @upport ol 

his dual role aa both Department of Defeaae spokeemm and head of Departmeat of Defense Pub&c 

Affeim. ASeistis”- ,_,pating the ASD krr bi-weekly prees briefinga. Interact tith the national print and 

bmadmwt media cm the ASITs behalf Provide the ASD with timely updates of current media etorits. 

Act as liaison with the offices of the Secmtazy, the Whit8 Ho- other Cabinet Staetariee and tbr 

Nafimud fkcuri~ Cod Ruvide @upport to the Secretary ofDefenae and Am&ant Sacmtary an 

fnquent intmnationd travel which includes a contingent of trmdiag media. Handle the MD’s d& 

schedufe and correspcnderm. : 

The white House Washingtm D.C. 

StaffAssiswzt to Llirectur of Legii&tiucA#ah coinb;po+nm, November 1995 -April 1996 

Wrote draRs and tstrespondebce fur &affSea-etarye ’ apprw;ll and ultimately the President% 

signam. v&i& often required xeeearcfr of various Adminietmtioa ii;scee and policies. caotdinated 

mass mailing8 to CongrG for the Pretident and other Seaior Administmtiotl o&Ma. Rowseed and 

vettud all incoming mail to the -dent fmm Congress. Trained and eupervised new interrm on White 

House procedure and prepptatiaa of White Eouee correspondence. 

. Drafted form letters and individual reapnses fur the Chief ofStPfte ’ rig&&. Acted bl) a-&&sun 6x 

Chief of Staff8 office to other Whita HM of3icee. Cabinet agetic, anti Congrasd oilices. 

Updated o&e manual Supetid and Mdinnted intern and vOtdnt& stafX * 

Mttropolitan Public Defenders Portland, Ore-n 

Altematiocs Stafl* February - May 1995 

Implemented new psjiehology expert reference techniques: Astited attornqe in finding viable 

alternativpe to prison for their eliente. Directed clienta in eucceeaful eearch for support, shelter, fiKlci 

and transportation. Upduted file* on resource materials. 

Southeast Mental Health Network (Practicum) Portland, Oregon 

Sociuiizcrtion Stafl A.&tan& Jtuxuar~r - June 1994 . 

Amisted stafI in teaching socialization skilIe to men& ill clients to e&se their integration back into 

society. Updated clienti’ confidential mpo&. Coordinated fknd raising to benefit em-cur&&r 

tbeatre activities. 

Additional Information: 

. 

5 . 

l TSSCI Clearance: Current 

l Proficient in Macintosh for Micrrrsoft Word 6.0, WordPerkt foi Wmdaws 5.2, Quorum, nad Inbye. 
, 

iI_ 

-- 
3528 
3529 

OIC-3-i’ (Rev. S-19-94) 

- 1 - 

OFFICE OF THE KDEPENDENT COLVSEL 

Dae of rranscnprlon 04/09j9R 

JAMIE BETH SCHWARTZ, white female, date of birth 

I 

home telephone number (a_, SCHWARTZ was advised of 

the identity of the interviewing Agents and the purpose of the 

interview. SCHWARTZ was interviewed in the presence of her 

attorney, MICHAEL W. ROCHE, 300 Harmon Meadow Boulevard, 

Secaucus, New Jersey 07094. SCHWARTZ provided the following: 

SCHWARTZ began work at the White House in January 1996, 

as a White House intern. SCHWARTZ was assigned to the White 

House Social Office where she worked as an assistant to Event 

Coordinator SARAH FARNSWORTH. SCHWARTZ was hired as a paid staff 

assistant in August of 1996, for the White House Administration 

Office (WHAO). SCHWARTZ's duties were basic clerical work, 

including typing, delivering memos, and answering the telephone, 

until January of 1997,' when SCHWARTZ was promoted to Operations 

Manager with the WHAO. SCHWARTZ's new duties included attending 

to requests of the White House employees concerning telephone 

lines, computers, and physical plant. In April of 1997, SCHWARTZ 

was named Special Assistant to the Social Secretary in the White 

House Social Office (WHSO). SCHWARTZ worked for Social Secretary 

ANN STOCK, and managed the invitation lists for all events held 

at the White House. SCHWARTZ sent out invitations, insured 

guests would be admitted to the White House, and managed the 

invitation list on the day of the event. In September of 1997, 

ANN STOCK left as Social Secretary, 

her place. _ 

and CAPRICJA MARSHALL took 

SCHWARTZ stated that all guests were required to give 

her their date of birth and Social Security Account Number, so 

that the guest could be cleared by the Secret Service and put on 

White House Visitors Access (WHVA) list. SCHWARTZ advised that 

Cabinet Members did not need WHVA clearance, and that at times 

White House employees who were pass holders would also be invited 

to White House events. 

-- 

Investigation on 04/08/98 at Secaucus, New Jersey Filc4 29D-OIC-LR-35063 

_. 

Date dmatcd 04/09/98 I 
3530 

29D-3IC-LR-35063 

Conrmuatlon of OIC-301 of JAFlIE BETH SCHWARTZ .On 04/08/98 ‘ .Pa_er 2 

SCHWARTZ stated that she did not know MONICA LEWINSKY 

personally, but knew her by sight, and knew that she was in the 

Office of Legislative Affairs(OLA) as a paid staffer. In the 

summer of 1996, SCHWARTZ had a conversation with Lieutenant 

BRYANT WITHROW, a uniformed Secret Service guard assigned to the 

White House. WITHROW told SCHWARTZ that the unofficial reason 

that LEWINSKY was forced to leave her job at the White House was 

that LEWINSKY had been caught in the Oval Office in a 

"compromising situation" with President CLINTON. SCHWARTZ 

assumed "compromising situation" to mean sex of some kind, but 

WITHROW did not give a detailed description. A few weeks after 

this, Lieutenant MATT FRITCH, a uniformed Secret Service Guard, 

told SCHWARTZ the same thing. FRITCH told SCHWARTZ that LEWINSKY 

was forced to leave her job at the White House because she had 

been caught in a "compromising situation" with the President in 

the Oval Office. SCHWARTZ believed Oval Office to include the 

President's study, and the dining room area. SCHWARTZ advised 

that she did not share this story with anyone else, as she did 

not know what to make of it. However, SCHWARTZ, over time, came 

to trust both FRITCH and WITHROW. 

Sometime after this, SCHWARTZ had a conversation with 

RAYMOND "TRIP" DONNELLY, III. DONNELLY had been given LEWINSKY's 

job at the OLA after LEWINSKY left. DONNELLY and SCHWARTZ had 

become friends. DONNELLY told SCHWARTZ that DONNELLY had been 

intenriewed on a Wednesday, hired on Friday, and started work on 

Monday. DONNELLY then said this was because LEWINSKY had to 

leave the White House quickly, and that DQN'NEL&Y had a friend 

that recommended him. DONNELLY was friendly with TIM KEATING. 

SCHWARTZ advised that the official reason LEWINSKY was fired from 

the White House was that LEWINSKY was incompetent at her job at 

the OLA. 

SCHWARTZ stated that when the KATHLEEN WILLEY story 

first appeared in the Washington Times, this generated talk 

within her peer group about WILLEY and LEWINSKY. At this time 

SCHWARTZ heard from someone that NANCY HERNREICH, Deputy Chief of 

Staff, had caught LEWINSKY and the President in a compromising 

position. SCHWARTZ could not recall who told her this. SCHWARTZ 

did recall speaking with CARMELIA 'TUTTY" FAIRBANKS and Secret 

Service Lieutenant WITHROW about these matters at that time. 
3531 

OIC-3022 (Rev. 8-19-91, 

29D-OIC-LR-35063 

Continuatton of OK-302 of JAMIE BETH SCHWARTZ .~n 04/08/98 .page 3 

SCHWARTZ advised that SCHWARTZ saw MONICA LEWINSKY at a 

White House Holiday Reception on either December 4 or December 5, 

1997. The reception began at 6:00 p-m_, and SCHWARTZ was the 

guest list manager. As such, SCHWARTZ was stationed at the East 

Visitor's Gate of the White House to allow the guests to enter. 

SCHWARTZ advised that as she waited for the guests to enter, 

WITHROW approached SCHWARTZ and asked her if she had put LEWINSKY 

on the guest list. SCHWARTZ replied, "No, she is the guest of 

someone." WITHROW then said, "We'll see what happens," and walked 

away. Also present at the East Visitors Gate was JEFF BOWMAN, a 

uniformed Secret Service guard who was acting as a Computer 

Assistant at that time. LEWINSKY entered as the guest of First 

Name Unknown-or- a white male, whom SCHWARTZ 

believed was some type of Chief of Staff at the Pentagon. 

SCHWARTZ stated that approximately 400 people entered to attend 

the Holiday Reception in the Diplomatic Reception Room of the 

White House. SCHWARTZ stated that after about an hour of 

checking guests in, SCHWARTZ left the East Visitors Gate and went 

to the ground floor of the West Wing, outside of the Diplomatic 

Reception Room. 

Shortly after SCHWARTZ arrived, she was approached by 

WITHROW, who asked SCHWARTZ if she had seen "her." SCHWARTZ told 

WITHROW that SCHWARTZ had just arrived and had not seen LEWINSKY. 

WITHROW then left without saying anything else. Minutes later, 

SCHWARTZ was approached by a member of the Presidential 

Protection Detail (PPD) of the Secret Service. This unnamed 

white male asked SCHWARTZ if SCHWARTZ had seen,,"her." SCHWARTZ 

asked, "MONICA?" The PPD Agent replied, "Yes." SCHWARTZ told him -. 

that SCHWARTZ had just arrived. The PPD Agent then said, with 

fervor, "We have to find her before Mrs. CLINTON sees her." The 

PPD Agent then "raced" away. (Description of this PPD Agent at 

end of this FD-302.) 

Immediately after the PPD Agent "raced" away, CAPRICIA 

MARSHALL entered the foyer outside the Diplomatic Reception Room 

where SCHWARTZ was standing. SCHWARTZ asked MARSHALL if MARSHALL 

knew who was there. MARSHALL rolled her eyes and said, "Yes," 

and went back inside the Diplomatic Reception Room. SCHWARTZ 

felt compelled to give MARSHALL a "heads-up" about the situation. 

Also present during these discussions was a voluntary Social Aid - 

Military Officer. SCHWARTZ did not find out what happened with 
3532 

OIC-Q:a ‘ (Rev 8-19-94) 

29D-OIC-LR-35063 

Contmuation of OIC-302 of JAMIE BETH SCHWARTZ ,~n 04/'08/98 .Page 4 

LEWINSKY at the reception after this. Some weeks later, WITHROW 

asked SCHWARTZ if SCHWARTZ had gotten in trouble because of 

LEWINSKY being at the reception, and SCHWARTZ told WITHROW that 

she had not. WITHROW stated to SCHWARTZ that he had not gotten 

into trouble either. 

SCHWARTZ advised that SCHWARTZ had first seen 

LEWINSKY's name on the guest list on the-morning of the 

reception. SCHWARTZ stated that she made a mental note of it, 

but did not tell anyone for a number of reasons. SCHWARTZ was 

very busy that day ,*and had a number of meetings to attend. 

SCHWARTZ also had not been given a reason to be alarmed .by seeing 

LEWINSKY's name on a guest list. 

SCHWARTZ stated she could recall three instances when 

she was notified to be wary of individuals invited to a White 

House event. On each occasion, THOMAS JANENDA, Chief of Staff's 

Office (COSO), requested that SCHWARTZ tell JANENDA how the 

person responded to an invitation. SCHWARTZ recalled that one 

individual was _ whose attendance at a White House 

function was deemed as politically embarrassing because of 

business deals- had been involved in. SCHWARTZ advised 

this occurred on two other occasions, but she could not remember 

the names of the individuals involved. 

SCHWARTZ advised that sometime around the end of . 

December 1997 or January 1998, SCHWARTZ had a conversation with 

JEFF BOWMAN. BOWMAN told SCHWARTZ that he had_&eard a story 

about a recent incident in which a Secret Service uniformed 

Sergeant, on detail at the Northwest Gate of the White House, was 

approached by MONICA LEWINSKY. According to the story, LEWINSKY 

told the Sergeant that she was a guest of BETTY CURRIE and the 

Sergeant called CURRIE to confirm this. BOWMAN told SCHWARTZ 

that the Sergeant then told LEWINSKY to go wait in. the lobby and 

"take a number." LEWINSKY found this comment to be rude and told 

the President about it. According to the story, the President 

called the Sergeant over, told the Sergeant to get his 

supervisor, and then told the Sergeant and his supervisor that he 

was very upset with the way LEWINSKY was treated. BOWMAN also 

told SCHWARTZ that ELEANOR MONDALE had also been a guest of the 

President that day, and that was why the Sergeant told LEWINSKY 

to take a number. 
3533 

OIC-303 (Rev. 8-19-941 

29D-OI,-LR-35063 

Contmuat~on of OK-302 of JAMIE BETH SCHWARTZ .On 04/08/98 .Page 5 

SCHWARTZ stated that she did not talk about her 

testimony with MICHELLE PETERSON, of the White House Counsel's 

Office. PETERSON told SCHWARTZ that the Office of the 

Independent Counsel wanted to interview SCHWARTZ, and that 

SCHWARTZ should not talk to PETERSON about her testimony. 

The following is a description of the unnamed PPD 

Secret Service Agent: 

Sex : 

Race: 

Height: 

Weight: 

Build: 

Age: 

Hair: 

Supervisor: 

Male 

White 

Medium 

Average 

Medium 

30's 

Medium brown (short, wiry) 

A.T. Last Name Unknown, in charge of the 

First Lady's Protection Detail 
3534 
3535 ~~___ 

In re: Grand Jury Proceedings Multi-Pagem May 19, 1998 

I 

Page ! 

1 of Columbia and the grand jury is investigating, among other 

2 things, possible violations of federal criminal law, 

In rc: 3 including pe+y, possible subornation of perjury and 

4 witness tampering related to the case of Jones v. Clinton 

5 Do you understand that? 

6 A Yes, I do. 

7 Q And you have a lawyer with you today? Is that 

8 correct? 

Tuesday, May 19, 1998 9 A Yes, I do. 

1 0 Q What is his name? 

presence of l full quorum of Grand Jury 97-2, impanelcd on 1 1 A Michael Roche. 

s*prember 19, 1997, comencing *t 3:z.K p.n. betor.: 1 2 Q Is that R-o-c-h-e? 

sooLoc(ou YIscNBsnc 

oeputy *ndqmdent Counsel 

1 3 A Correct. 

MARY ANNE **Km 

-CRANE 

1 4 Q You understand he cannot be in here with you, bl 

A¶soclate Indecpcndent Counsel 

Oftlcc of IndcpmMent Counatl 

1 5 if you have a question about anything you may go out x any 

1001 pInnsy1vulia A"ml"., YQlxhYtst 

suite 490 mrth 1 6 time. - Do you understand? 

Washlnqton, D.C. 20001 1 7 A Yes.. 

1 8 Q Do you understand that you have privilege agains 

1 9 self-incrimination? 

21 0A Yes, I do. 

2 1 Q Do you understand what that is? 

2: 2 A Yes. 

2: 3 Q Anything you say can be used against you. Do you 

21 4 understand that? 

2: 5 A Yes. 

Page 2 

1 PROCEEDINGS 

2 Whereupon, 

3 JAh4IE SCHWARTZ 

-I 

Page L 

1 

2 

3 

4 

5 

6 

7 

8 

9 

0 

1 

2 

3 

4 

5 

5 

7 

3 

? 

1 

I 

! 

1 

I 

i 

Q And you know that you are under an obligation tc 

tell the truth? 

A Yes. 

5 tbeForepezsonoftbeGrandJury,wasexaminedandtestified 

6 as follows: 

7 JXAMINATION 

8 BY MR. WISENBERG: 

9 Q Would you state your name for the record, please? ’ , 

0 A Jamie Schwartz II 

I Q And how do you spell Schwartz? 1 

2 A S-c-h-w-a-r-t-z 1: 

3 Q Ms. Schwartz, my name is Sol Wiser&q. I’m with 1: 

4 the Office of Independent Counsel I’m an attorney with that 11 

5 office, and this is Ms. Wii who will be doing the 1: 

6 questioning of you. She’s an attorney with our office. l( 

7 Jii Crane just walked in, bes ’ an attorney with our office. 1: 

8 Thisisthegrandjurycourtreporterandthemembersofthe 11 

9 grand jury. I! 

0 I’m going to briefly go over your rights and 2( 

1 responsibilities as a grand jury witness. When I ask you for 21 

2 a response, I’ll ask for an audible response, okay? 2: 

3 A Yes. 21 

4 Q First of all, this is a federal grand jury 24 

5 impaneled by a United States District judge for the District 25 

Q And that you have to answer the questions 

truthfully? 

A Yes. 

Q You’re aware if you were to not tell the truth that 

it would mean thepe could be perjury charge. You undas&~ 

that? 

A I understand that_ 

Q Now,weareallbotmdbyanaathofsxxecy. ‘llxre 

are certain exceptions which I won’t go into, but, by ant 

large, it means wz can’t go and blab about what goes on bore 

inthegrandjurytodayunlessthelawallowsustoorunlss 

a judge allows us to. Do you understand that? 

A I do understand that. 

Q But you are not so bound. That’s up to ‘you and 

your attorney whether or not you talk about wbat went on her 

today. Do you understand that? 

A I do understand that_ 

Q All right. We have several categories of people 

who testify in front of a grand jury. Some pebple are 

targets. ‘IM means those are people who are probably going 

to be indicted. You’re not a target Do you understand 

that? 

Diversified Rcuorting Services, Inc. (202) 296-2929 

Page 1 - Page 4A 
3536 ~_.P 

In rc: Grand Jury Proceedings Multi-Pagem 

c 

May 19.1998 

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 

A I do. 

Page : 

Q Then u-e have subjects and witnesses. A subject I 

a person who is not quite at target status, but the grand 

jury has concerns about them. You arc not a subject. Do you 

understand that? 

A I do understand. 

Q And a witness is a person who just has information 

the grand jury wants to hear about. Do you understand that? 

A Ido. 

1 

f 

I 

1 

1 

1 

1 

1 

1 

1 

1 

1 

28 

2 

2 

2 

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, 

1( 

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1: 

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2: 

Q You are a witness. Do you understand that? 

A I do. 

Q We Can’t promise you YOU’ti alWayS be a Witf’CSS, 

that you could never be a target. We can’t make that 

promise. You understand that? 

A I do. 

Q These are informal distinctions, witness, subject 

target, that have been ma& over time. Do you understand 

that? 

A I do understand. 

Q All right. If there’s any question I ask that is 

not clear or that Ms. Wirth asks which is not clear, please 

let us know and we will re-ask it. 

A Absolutely. 

Q Do you understand your rights and responsibilitie: 

as a grand jury witness? 

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1 A Yes, I was. 

2 Q And when did you begin your work as an intern? 

3 A Mid January of 1996. 

4 Q And what office were you assigned to as an intern? ( 

5 A The SOhal Off%%. 

6 Q And how long did you work there as an intern? 

7 A Until I was hired by the White House at the end o: 

8 July of 96 ‘ and then my papexwork went through August 1st and 

9 that’s when I was on payroll. 

IO Q All right. And you began working, you said, in 

I 1 August of ‘96 with what office? I’m sorry. 

12 A office of Administration. 

3 Q AII right. And what was your role there? 

4 A I was a staff assistant, primarily responsible for 

s clerical duties, phone answerin& support to some of the 

Page t 

1 A I do. 

2 MR. WTSENBERG: All right_ I’ll hand you over to 

3 Ms. Wix-th for questioning. 

4 

5 Q 

6 A 

7 Q 

3 city? 

3 A 

1 Q 

I A 

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3 A 

t Q 

j A 

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7 A 

5 Q 

BY MS. WlRTHz 

Can you tell us how old you are? 

I’m 23. 

And wlxre do you presently reside by state and 

In Hack-a&, New Jersey. 

Okay. And are you cunently employed? 

No, I’m not. 

Okay. And when were you last employed? 

March 6th was the last date of my employment. 

March 6th of ‘98? 

YeS. 

And what did you do? 

I worked in the white House social office. 

And for how Ioog had you been an employee of the 

P WhiteHouse? 

1 A IwashiredonAugust1,1996. 

I Q And in what capacity? 

! A I was first hired as a staff assistant in the 

I Office of Administration. 

I Q Okay. And prior to that, had you been an intern in 

i the White HOUX? 

6 senior i&e1 people in my office. 

7 Q And how long did you hold that job? 

8 A I left that office in April of ‘97. 

9 Q And what job did you get after that? 

10 A I became special assistant to the Social secmary, 

II which was the position I left in the social office.. 

12 Q And who was the person you were special assistant 

:3 to? 

‘4 A Ann Stock. 

5 Q Anddidtherecomeatimewhensheleftherjob 

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social secretary? 

A 

Q 

A 

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A 

Q 

YeS. 

When did that occur? 

She left in September of that year, of ‘97. 

And who took her job? 

Capricia Marshall. 

And did you function as’M.s. Marshall’s assistant 

for a while? s 

A ti-hmm. 

Q until you left? 

A Yes. 

Q Why did you leave the White House? 

A I wanted to relocate. My family is from New Jersey 

and I wanted to go back. 

Q Okay. All right. Now, did you know Monica 

Lewinsky? 

A 

Q 

A 

Q 

A 

Q 

A 

No. 

Had you ever seen her? 

Once. 

where did you see her? 

In the White House. 

Do yoti remember where? i 

It was passing in a hallway Ed I didn’t really 

thinltanythingofit. Idm’t Ilzfnem~theexact locaticm. 

5 Q Was it in the East Wing, West Wing? I 

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1 .4 I believe it was in the West Wing. It was 

2 &finitely on that side of the house. 

3 Q And did you know who she was by name? 

4 A I did not know her at that time by name. 

5 Q Why does that stick out in your mind? 

6 A Because later on when 1 became familiar with whl 

7 she was, I had remembered, oh, I had seen that person. 

8 Q Was she working in the white House at the time? 

9 Doyouknow? 

May 19, 1998 

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A I believe so. You know, we all have passes in the 

White House and they’re sort of &marked by color, so, you 

know, the color of her pass would lead me to believe that, 

but interns can have colored passes. 

Q What color was her pass that day? 

A Blue, I believe. 

Q And that denotes a permanent employee? 

A It can denote an intern or a permanent volunteer a 

Well. 

Page 1 

1 A At the time, he was a sergeant in the Uniformed 

2 Division, assigned to the Special Operations section. 

3 BY h4R. WISENBERG: 

4 Q How do you spell his last name’! 

5 A I think it’s F-r-i-t-c-h. 

6 BY MS. WIRTH: 

7 Q All right. And do you remember how the subjec 

8 came up wilh him? How be came lo tell you about Monica and 

9 why she was fired from the White House? 

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that she had left the White House, that she no longer worked 

there? 

A Yes. 

Q And do you remember how you came to learn that? 

A I came to learn it two ways. I heard sort of a 

rumor or unofficial version of the story and I also heard an 

1 official version of the story as to why she left. 

Page 10 

2 Q Which did you hear first? 

3 A I believe I heard the unofficial version first. 

& Q What did you hear? The unofficial version. 

5 A The unofficial version I heard was that sly was 

6 abruptly asked to leave because she was found in a 

7 compromising position with the President. 

3 Q AIlright, Andwhodidyouhearthatfrom? 

) A I heard it from -several people at different times 

1 andsoIwouldhavetosaymorethanonepersonbutIdid 

I hear it from some Secret Service officers. 

2 Q Okay. Just by to keep your voice up. 

I A Secret Service officers. I’m sorry. 

1 Q Okay. And how many? 

i A How many officers did I hear it from? Two. 

i Q And what are their names? 

1 A Matt Fritch and Bryant Withrow. 

i Q And do you pber which one you beard it from 

a first? 

1 A Matt Fritch 

I Q And did you have a social relationship with . 

! MI. Fritch? 

I A YeS. 

1 Q And do you know what his position in the White 

i House was. what his iob was? 

conversation. Of course, it was a while ago. But an 

innuendo had been made about sort of the President ant 

flirtation and then this story sort of evolved from there 

and snowballed. 

Q Were others present when he told you this? 

A -When he told me the story of unofficially why sh 

left? No. But others were present at a time when there was 

sort of gossip and kidding around about the flirting. 

Q Okay. Now, do you remember when he told you this? 

When Maa Fritch told you what you just told us? 

A The timeframe, you mean? 

Q In relation to when she was fired. 

A It was definitely afterwards and I believe it was 

somewhere in March of ‘96, but I can’t be certain that that’s 

the exact time. 

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Q And what exactly, to the best of your memory, dc 

you remember that he said to you about why she was fired? 

A He basically told me exactly that, that she was 

found in a compromising position with the Resident &d I 

didn’t ask any questions, I didn’t feel that it was 

appropriate for me to ask, so I didu’t - you know, I didn’t 

ask for details or anything of that nature. 

Q Did he -tell you how he knew that? 

A He insinuated that he knew because another ofice 

whowaspostedoutsi&oftheOvalOfficewasawitmsto 

that, I guess. 

Q When you say insinuated, did he say that or - 

A He didn’t say to me. you know, “Joe told me exactly 

on this date that this had happened.” He sort of ma& a 

reference to it and said “You know, I have a friend who was 

posted at this post.” 

Did he tell you the friend’s name? 

He did not. 

h4R. CRANE: Can I ask one question, Ms. Wirth? 

Ms.wrRTH: Yes. sure. 

RY MR. CRANE: 

It may be kind of obvious, but how did you 

understand the term - what did you understand, ma’am, the 

term compromising position to &an? 

A I understood it to mean, without asking for 

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1 clarification, that it was some sort of inappropriate 1 Q Now, what did Bryant Withrow tell you? 

2 physical act. 2 A This was at a later time than Matt had told me. 

3 BY MS. WRTH: 3 Q How much later? 

4 Q Did he tell you specifically where this had 4 c A Gosh, I would have to think at least a couple of 

5 occurred? S months, if not almost a year. It was definitely -- it was 

6 A In the Oval Office. 6 certainly after Man had left the Special Opations section, 

7 Q Did he define it more? 7 so that would put it at least, I believe, in September that 

8 A No, he said the Oval and at the White House, the 8 he left Special Operations, so at least a couple of months. 

9 Oval is a generic term used for the sort of suite that he 9 And hc had also not made a direct link. He had also 

0 actual Oval is and then there’s a study and a private dining 1 0 insinuated something. And, again, I didn’t ask for details 

1 area off of the. Oval, but we call that whole sort of compound 1 1 or sort of question further. 

2 area the Oval, so I don’t know the specifics as to which 1 2 Q How did that come up with Bryant Withrow? 

3 location in the Oval. 1 3 A It was actually in sort of a jesting conversation 

4 Q Did you discuss this with Mr. Fritch on more than 1 4 You know, occasionally Secret Service goes on the road 

5 one occasion or just the one time? 1 S travels with the President and/or First Lady, you know, 

6 A No. The one time that he did tell me and then I 1 6 whatevedhe case may be. And sort of innuendo was made 

7 never brought it up again. 1 7 to how agents on the road can sort of be a little bit 

8 Q Did you ever tell anybody that he had told you 1 8 philandering and what not and Bryant made a comment to the 

9 this? 1 9 sort of extent of, “Well, you know, theyre ’ not the only 

:0 A No. 2 0 ones.” And it sort of snowballed into a conversation of tk 

1 Q Did anybody else ever tell you this besides 2 1 President and his activities. 

.2 Mr. Fritch? 2 2 Q And do you remember what Mr. Withrow said to yan 

3 A Yes. 2 3 about Monica Lewinsky? 

4 Q who? 2 4 A All he said is, “You know the name Monica, right?’ 

5 A Bryant Withrow. 2 5 And I said, “Yes.” And that was the extent of the 

Page 14 Page ; 

1 Q And he is also a Secret Service employee? 1 conversation. It didn’t go further than that. 

2 A Yes, be’s a lieutenant 2 Q So it was by implication that he was discussing - 

3 Q Is he also uniformed? 3 A YeS. 

4 A He is uniformed. 4 Q -- what type of behavior involving Monica? 

5 AJUROR: MayIhavethelastnameagain? 5 A Sexual behavior. 

6 THE WITNESS: Bryant Withrow. , 6 Q Did he say with who she was sexually involved? 

7 BY MS. WIRTH: 7 A ‘Ibcimpticationwbu~hca&edmif~knewhaname 

8 Q W-i-t-h-r-o-w? Right? , B I took it to mean tE! President. He never articulated thz 

9 A Ye.% , 9 to me directly. 

0 BY MR. WISENBERG: II D Q Okay. You took it to meafi that bemuse he said 

1 Q Bryant? 1 1 therearfsotks? 

2 A Bryant. Yes. With at. 1: 2 A Yes. Exactly. 

3 BY MS. WIRTH: 1: 3 Q or they’re not the Only ones? 

4 Q B-r-y-a-n-t. Is IX Mr. Fritch’s supervisor? 11 4 A Right 

5 A At the time Matt worked for Bryant, yes, but 1: 5 Q Okay. All right. And has anybody else told you 

1r 5 about a relationship between Monica and the President otha 

1: 7 thanthcsetwoSecrd~anployeesthatyou’vetoldus_ 

II 3 about? 

I! 7 A Never mentioned it to me directly. No. 

2 0 Q Okay. And whem you mentioned earlier that t.b 

2 1 wassomcsortofgossipaboutfIirtationandsomoat,did 

2 2 that occur bcfom you Found out what you found out from Uatt 

2 3 Fritch or &envards? 

2 4 AAfter. I 

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6 Matt subsequently got transferred and was no longer under 

7 Bryant. 

8 Q Did you also &e a social relationship with 

9 Mr. Withrow? 

10 A Yes. 

11 Q Did you have a closer relationship with either of 

12 those two? 

3 A Matt. 

.4 Q Matt was the closer? 

S A IVIm-hmm. S Q Okay. And what was the context of that? I 

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1 A Just -- I couldn’t really put it in a context. 1 Q And where had he worked bsfore he took Monica’s 

2 It’s sort of being there and being engulfed in the situation, 2 job? 

3 you just sort of hear things and let them roll off your back, 3 A I do not know that. 

4 I guess, is the best way to put it. It’s not really 4 Q Was he in OLA? In the Office of Legislative 

5 something I paid close attention to. 5 Affairs? 

6 Q Is this one particular instance that you’re 6 A To my knowledge, I don’t know. We didn’t real11 

7 thinking of? 7 discuss it. I believe he was not a: the White House prior to 

8 A No. 8 his being hired in the Office of Legislative Affairs. 

9 Q No? Just general gossip? 9 Q Did he tell you who hired him? 

0 A Just general gossip. Exactly. JO A He didn’t tell me who hired him. 

1 Q Any particular person you can think of who said 11 Q Did he tell you if anyone recommended him? 

2 anything specific? 12 -A Well, I know that Tim Keating was involved in that 

3 A Not b&&es those two that I mentioned. I mean, 13 becausehewasthestaffdireetorattbetimeintheOffree 

4 there was a later date, after this story had come out 14 of Legislative Affairs, so he as the staff director has a lot 

5 Q Who is Raymond Trip Donnelly? 15 of input and decision making powa in that capacity. If you 

6 A He is the person that took Monica Lewinsky’s job at 16 wPretoaskmetohedgeaguess,IwouldsaytbatTimKeatin 

7 the White House, to my knowledge. 17 was definitely involved in that, but I don’t know that 

8 Q At the Office of Legislative Affairs? 18 firsthand. 

9 A Yes. 19 Q Is Mr. Keating a friend of Mr. Donnelly’s? 

0 Q Is he a friend of yours? 20 A To my knowledge, yes. 

1 A Yes. 21 Q And do you know that btmuse. Mr. Donnelly told you 

2 Q And what did he tell you, if anything, about how he 22 that? 

3 got Monica’s job? 23 A I know that just from seeing them at the White 

4 A I became friends with Trip quite a time after 24 House together and sort of -- you know, eomraderie and out 

5 Monica had left the White House. 25 soci&y. 

Page 18 Page 20 

1 Q And Trip is a nickname? J Q Do you know whether Mr. Donnelly knew Mr. Keating 

2 A Yes. He’s Raymond Donnelly, I11 and so he goes by 2 before he took the job at the Office of Legislative Affairs? 

3 Trip as triplet or, you know, the third. Pretty clever. It 3 A I do not know that. 

4 tookmeayeartoftgureitout. ButIbadbeuunefriends 4 Q Did Mr. Donnelly ever tell you anything about why 

5 with him some time after she had left the White House and as 5 Monica Lewinsky left the White House? 

6 our friendship evolved, we spent a little bit more time out 6 A He told me that he knew the unofficial version of 

7 sociallyafterwork,gettingadrinkorwhatno~andwcwae 7 thestoryortbeNmorvasionofthcstory,buthcwastold 

B taIkingabouthow~~youknow,himdatthesametime 8 initiaIIywhenhewashimdthatitwasbeeausesbewasnot 

9 or around the same time. 9 performing to the level that her supervisors had anticipated 

3 And that’s how the Conversation evolvad, “Oh. wtren 10 or had wanted her to, I guess: 

I were you hired?” And “I was hired at this date.” And I I J Q Then that was the official story he ‘ told you? 

2 said, “Oh, you know, who did you replace?” Because that’s 12 A Yes. That’s what he was told. 

3 sat of a big thing at the White House, who left, you know, 13 Q Did he tell you who told him that? 

I whose job did you take? And so he told me that he took 14 A He did not. 

s Monica Lewinsky’s job and it was a pretty fast hiring 15 Q Is that the only person that you’ve heard the 

5 process. 16 official story from, Mr. Donnelly? 

1 Q What did he tell you about how quickly he was 17 A Yes. Besides hearing it on the news in January. 

s hired? :. 18 Q Okay. And did Mr. Donnelly ever tell you any 

9 A It was in a matter of days. I would say - and, 19 unofficial story as to why she was fM why Monica was 

) again, I don’t know the dates definitively, but it was 20 fired? 

I somethingtotbenatureof.youknow.bewasinterviewedona21 A He never told me directly. He insinuated that he 

2 Tuesday, hiral oo a Wednesday and came to work on a Monday or 22 knew the Unofficial story. 

3 somethingofthatnature. OrhiredonWednesdayandcameto23 Q How did he do that? 

0 work Friday. But very quickly. A lot more expeditiously 24 A We were having a conversati& about something of 

5 than a lot of other people are hired at the White House. 25 that nature, being on the road or whatever, and a friend of 

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1 ours actually -- a friend of his, someone I knew by name and 

2 rbe name escapes mc now. but had gone to the Pentagon and he 

3 said something to the effect of, “Oh, like Monica.” 

4 And I said -- you know, I sort of just shrugged it 

5 off and didn’t really pursue it any further and he said, 

6 “Well, you know the story about why she really left.” And I 

7 said, “Well, I’ve heard rumors. I didn’t witness anything 

8 myself, so, you know, I can only say that I heard the 

9 rumors.” He said, “Oh, yeah I heard the rumors, too.” 

1 0 Q Is he still working there, by the way, 

1 I Mr. Donnelly? 

I 2 A To my knowledge, yes. The last time I was there, 

1 3 again, was in March. 

1 4 Q Did you ever hear anything about any specific 

1 5 person in the White House catching Monica and the President 

1 6 together or finding them together? 

1 7 A Yes. 

1 8 Q What did you hear? 

1 9 A I heard that Nancy Hemreich caught them togethei 

2 0 in the Oval Office. 

2 1 Q And do you remember who you heard that from? 

2 2 A I believe Matt was one of the people that told me, 

2 3 but I know I heard it from another source and I don’t know, 

2 4 I don’t remember who it was. 

2 5 Q Was it somebody in the White House that you heard 

Page 22 

1 it from? 

2 A Yes. 

3 Q Do you know if the source you heard it from in 

4 addition to Matt was somebody in the Remet Service or 

5 someone who was just an employee in the White House? 

6 A I believe it was just an employee. Later on, I 

7 heard it from another Service off&r, but that was much 

8 after I had initially hear_d it from Matt 

9 Q Who was the other person that you heard it from? 

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A An officer named Jeff Bowman. 

Q And is he a Secret Service Uniformed person? 

A He’s Uniformed. 

Q And did you hear it from him while you were still 

working at the White House? 

A Yes,Idid. 

Q How did that come up? 

A It came up after a conversation related to an 

incident that occurred ittXJccunbu of ‘97 and Monica Lcwinsky 

camctotbtWhittHouseinDecanbcrof’97andinJanuary~ 

were talking about, you know, whatever was going on in the 

news -- 

Q We is you and Bowman? 

A Yes. And he said, “Well, you know the original 

story, right?” And I said - you know, I sort of agreed, and 

I said, “Yeah, I know.” And he said, “You know, Nancy was 

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the one that found them.” And I said, “I’ve heard that, buL 

you know, I don’t really know.” 

Q Do you know u-hat Mr. Bowman’s post is? 

A He’s assigned to Special Operations section, w +4 L 

is the tour officers. 

Q And that was where Mr. Fritch and Mr. Withrow wex 

as well? 

A Yes. 

Q Okay. Now, you said that Monica had come to the 

White House in December of ‘97. 

A Yes. 

Q Was that for a function? 

A Yes. 

Q And what function was that? 

A I believe it was the December 5th holiday reception 

and, again, I can’t recall definitively, but it seems to 

stick in my mind that that’s when it was. And it was one 

of the standard holiday receptions that the President and 

First Lady host. There wue four of them. And they could 

have anywhere from 300 to 600 people there, with a mixed 

variety of people on the invitation list 

MR. WISENBERG: Page 120 on your chrons. 

BY Ms. WIRTH: 

Q And what was your role, if any, that night? 

A In my assignment in the SOCi~ OffiCe, my piimar 

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role was to liaison with Suxet Service and be down at the 

gate as guests were admitted into the White House and 

trouble&ootandmakesurethattkyweresortoftakcncare 

ofandacconnnodatedandwbatnot. Andiftbemwereany 

aecuiity problenls with geS.ing their ckalancc taken caln of, 

Iwouldhandlethatastfrestaffmemberinchargeoftht 

gate. 

Q Did you haea guest list in your possession? 

A Yts,Idid. 

Q For how long had you had the guest list before tk 

event? 

A Wedoaninvitationlistan~fromthrawecks 

tooneweekout,ideaUy. Weliketoget’itdoneasearlyas 

possible, but sometimes, of CouTsc, there arc late additions. 

OntbeseparticularFeoepti~becauaatheyamsobigand 

hecause invitations do get dropped so late, up until tha 

night of - I meaq until 4:00 in the afternoon we’re 

receiving responses. 

We’re also calling people to see if they’ll he 

coming so that they won’t be hassled at tbc gate. You know, 

they’ll he on the list already. 

The particular list for that event was compiled 

verylateinthedayhecausewedidnothaveaIIt.hs 

respons~thatweneeded. Weaddedti5itvu-ylateintbe I 

day as well. It was not even in its complete form when I I 

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opened the gate. 

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Q And this is what gate you were stationed at? 

A The east visitors gate, which is between the East 

Wing and the Treasury building. 

Q And had you seen Monica‘s name on the guest list? 

A I did I saw it late that afternoon, if not that 

evening, somewhere in the ~i~~~d of four or five 

o’clock. 

Q And was she accompanying someone else to this 

event? 

A Yes. She was the guest of somebody. 

Q Do you remember who that was? 

A I believe his name was 

Again, definitively, I can’t remember. And be is also 

staticmedorworksatthePentagon. Oratthattimeworked 

atthePentagon_ Idon’tknowwhathedoesnoworwherehe 

is. 

Q Okay. Now, for about how long went you stationed 

at the east gate? 

A I would say at least an hour to an hour and a half. 

Q Okay, And did you see Mr. Withrow that night? 

A Yes, lx was at the gate. 

Q And did he say anything to you? 

A When I got to the gate, he asked me if I had seen 

her name on the list and I said yes. 

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Q Okay. And did he say anything else? 

A The conversation was very quick and abrupt because 

Ididn’trPallywanttoget~~detailswithhim, Hesaid, 

‘Did you see her name on the list?” I said, “Yes.’ He said, 

“Did you put her on there?” And I said, “No, she’s tbc gued 

ofsolmhdy.” Orsomethingtothat~. Andthatwasth 

extent of it. offiax Bowman was also patty to that 

conversation. He F in the vicinity and overheard it. 

Q Did Mr. Withrow say to you anything Iike “We’ll see 

what happens”? 

A Yes, he did later on. As we opened the gate, be 

said - I believe it was achmlly while she was walking in or 

approaching the gate, he said, “We’ll just see what happens.* 

Q Okay. And did you understand what he meant by 

ihat? 

A I took an implied meaning. I didn’t - and I 

thought it to mean, you know, when she actually sees th 

Pxesident or whenhe sees her. 

Q Okay. Now,didhi.r.WiUmwaskyottwhetberyouhad 

seen Monica at some point? 

A Later on, once the gate bad closed, I bad gone 

inside, and that’s when be approached me inside. 

Q When you say inside, you mean inside ttie white 

House? 

A Inside the WhiteHouse. Sorry. 

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Q And did you actually go to the party at that point? 

A Yes. I wxs on the ground floor of the WiGbe House, 

which is where the receiving line was taking place. 

Q And was the President there that night? 

A Yes. The President and First Lady were both 

present. 

Q Okay. And at this point, Mr. Withrow walked up to 

you? Is t&t correct? 

A Yes. He had gone in before me. He had left the 

gate before I had actually closed thegate. And then I came 

in and was walking down th: corridor on the ground floor when 

he sort of came up from almost hehind me, thE side, tapped me 

on the shoulder and said, “Have you seen her?” 

And I said something to the effect of “I assume 

you’re talking about MO&X” I said, “I haven’t s6ea her 

since1 came in, I just walked in. I mean, y&u literally 

walked up behind me as I came in. I’ve not seen her.” And 

fie walked away. 

Q Okay. Did any other Secret Service person come up 

b you at that point? 

A Yes. 

Q who came up to you? 

A A PPD officer, a Presidential Protective Division 

agent, came up to me and said, “Have you seen her?” And I 

assumed again that x were talking about Monica and I said, 

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“I just got here. I saw her at the gate. I haven’t seen her 

Page 28 

since I got in.” And he said to me, “Well, we’d better find 

her before Mrs. Clinton sees her,” 

Q Okay. And for the benefit of the grand jury, the 

PresidentiaIFVotectiveI3ztailpasonisapersonwhowlearsa 

suit, not in uniform. 

A Yes. He’s in a suit. Plain&&es. 

Q AmembePoftheSccretServi~. 

A AmemberoftbcSecretSefviceassignedtoprotect 

the President and/or First Lady. 

Q Do you know this person’s name? 

A Idonot. 

Q Did you recognize the person and know tlxxn that 

night? 

A Yes. ~~thembecausChcwaSOnthe 

detail for quite some time, so I was used to seeing him 

around at events, in the house, things of that nature. 

Q Okay. But you didn’t know his name that night. 

A No. I still don’t know his name. 

Q Can you describe him for the grand jury? 

A Sure. HE was probably medium to a little bit tall, 

five-nine, five-ten. A little bit slender. Brown hair, 

curly on top but close cut. No facial hair. Young. I would 

say probably somewhere the ag;of 30 to 35, if I had to 

guess. 

Page 25 - Page 28 

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Q Race? 

A White male. 

Page 25 

Q Okay. And is that the only time he’s ever 

discussed Monica with you or raised the subject of Monica 

with you? 

A Yes. 

Q Why would he approach you on this subject? 

A Because most of the detail knows -- the social 

off&, just for background, only has five permanent staff 

munh. Wc’x tbfz five members responsible for sunning any 

social event that takes place in the hollse. Most of the 

detail, because I’m responsible for liasioning with Secre 

Service over security issues and guest lists, recognize me as 

thepersonthatisatthegate,soIassume becausehesawme 

andknewthatIwasassignedtothegatethatnight,hecame 

up to me. That’s the most logical conclusion that I can make 

from that_ 

Q And how did he leave you? Did he leave you 

rushing? 

A He son of zoomed off. You know, he wasn’t running 

by auy =, they don’t run, but I mean he went off 

determined to do something. 

Q And do you know what happened after that? 

A I have no idea. 

Q Did you speak to anybody else about Monica that 

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Page 30 

A I spoke to Capricia Marshall. 

Q How did that come about? 

A Since two officers ’ had sort of - Bryaut and this 

PPD agent had mentioned to me, I thought that it would be 

advantageass of me to let my boss know since the President 

andthcFvstLsdywoutdbetheftrstoaesthat_shewould 

bethefirstanethatthey~wandsowhenshecameoutof 

tbediplomaticrecepti~room,whichwaswharshewas 

standia&Isai4”I)oyouknowwho’sontbcgucstIisZcmd 

that she’s ti?” And she said, “Yes, I know.” And she went 

back in the room and we didn’t discuss it firrther. 

Q How did she react primly, if at all? 

A Sort of poker face. Didn’t really get too excited -~_ 

or disappointed or -- 

Q Did she roll her eyes at all? 

A She made some sort of - you how, gesture. I 

don’t know that I would say it was rolling, it was sort of - 

all right, you know, business as usual kind of look. It 

wasn’t one of frustration or anything like that_ 

Q And you said to her - what did you say to her 

again? 

A 1 said something to the effect of, “Do you know 

who’s on the list? Do you know who’s here?” And she said, 

“Yes.” 

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Q And for the record, Capricia Marshall at that point 

was your boss? She was the social secretary? 

A Yes. 

Q And she had replaced Ann Stock, your previous bo d _ 

A YeS. 

Q Had you ever discussed Monica Lewinsky with 

Capricia Marshall before? 

A Before that day? 

Q Yes. 

A No. 

Q Well, how is it that you said to her something lo 

the effect of “Do you know who’s here?” How did you exm 

her to know? 

A Because it was just implied Because of the rumors 

that circulated around the White House, you know, about this 

kind of‘thiog tid Capricia’s pnvious position was special 

a&stanttotheFrrstLady~shewasherpersonalas&tant, 

I tcuk a natural assumption snd knw that sbc would &now who 

I was taIk.ing about. 

Of course, I would have clarified it for her if she 

had asked further, but she didn’t and that was my assmnption 

and implication. It wasn’t because I had discussed it with 

her earlier. 

Q And did you evef physicaLly $& Monica that night? 

A Ye.% 

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Q When you checked her in at the gate? 

A Yes. 

Q And did you see her after that? 

A I don’t beIieve I did, although someune told w: 

thatsbewas;wallcingbyandIwasn’tpayingattentionbecaus 

I was taIking to somebody else; 

Q ~d~u~ha~~y~~~~ 

Ms. Marshall abotft Monicas ’ presence that night? 

A No. 

Q Hasanyoneeverquestionedyouaboutwhyshewasou 

tbeguestlist? 

-. A The only person that did was Withrow that night 

whenheaskcd,‘Doyoukllowwho’sontheglXstList7” or 

“~dyouput~~~~~~ ~~~~~ 

asked me about that night in terms of her being there. 

Q I’m just going to change subjects for a moment. 

DoyoukJXJwwbuhucapricieMarshellisfriendswitbvunon 

Jordan? 

A Ibc&veSheiS. 

Q Okay. -Have you ever sun them tog&her, Vunon 7 i 

Capricia? 

A Mm-hmm. 

MR. WISENBERG: Is that a yes? 

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j_; Grand Jury Proceedings Mull 

page 3: 

THEwlTNEss: Yes. 

BY MS. WIRTH: 

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Q When you have seen them, was it in the White House 

or outside the White House? 

A I would have to say that I’ve seen them engaged ir 

conversation at the White Hose and it was most often Vemo 

was a guest of the CIintons at a function, a reception or 

some sort of ga&&ng. It was never a one-on-one meeting. 

Q Okay. And do you know if Vernon’s Jordan wife 

worked at any point in tlx social office? 

A Yes, She’s a volunteer in the social office. 

Q what is her name? 

A Ann Jordan. 

Q Okay. And for how long has she worked there? I 

you know. 

A I don’t know. Sfie was always sort of a figure 

there, as long as I was there as an intern, as well as a 

staff manbar, so that covers two years right them. I don’t 

know about anything before that. 

Q Wasshetherethatnightattheparty,atthe 

Christmas party that you’re talking about? 

A Deceolbersth? 

Q Mrs. Jordan. Yes. 

A No. To my Imowledge, she was not. 

Q Do you know her persomiIly? 

ii- Pagem May 19.1998 

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Page 35 

said anything to me about it and I turned over all the 

documents that were requested. And that was sort of the end i 

of the conversation. 

Q When you say youve ’ turned over all the documents 

that were requested, do you mean in response to subpoenas 

from the Office of the Independent Counsel? 

A Yes. Document requests. 

Q Did you ask Mr. Withrow whether he ever got in any 

trouble over this or did he offer that he had not gotten into 

trouble over this? 

A Ididnt&. ’

Q That subject didn’t come up, whether he got into 

trouble or not? 

A 1 sort of madt a joking comment of, “Are you going 

to be okay?“ And, you know, he just shrugged it off, 

laughed. 

Q Okay. Have you had any contact with Mr. Withrow 

since you’ve left the White House? 

A The week after I left the White House, which was -- 

I don’t know, the 12th or the l&l~ 

Q This is of what month now? 

A March Because I left March 6tb, so it was the 

week after. I had spoken to him on the phone, just a sort of. 

touch base convexsation, how you doing, fine, how are you. 

And that was it. It was maybe three minutes. It wasn’t 

Page 34 Page 3( 

1 A Yes, we’ve engaged in conversation. We’ve heen in 1 anything at length. 

2 sort of staff meetings together, things like that. Not 2 Q Youcakdhim? 

3 socially, though, just from work. 3 A I~~~~~Ho~,~ly,~~~ 

4 Q Have you ever discussed Monica with her? 4 somebody in my old off& and I said, “Well, transfix IIX

5 A Never. 5 down. .I’11 see if be’s there, 1% say heI.lo.~ 

6 Q With Mrs. Jordan? 6 Q And you were actually able to reach him? 

7 A Never. 7 A Yes. 

8 Q Doyouknowwhetbcrsbaisaware,Mrs.Jrndan,of 8 Q And whatid you speak about? 

9 the rumors about Monica Lewinsky and the President? 9 A ~askedmewhat~wasupto,heaskedmeifIwas 

0 A I do not know that. 0 all settled in my new apartment; Basic relocating questions 

1 Q Did those rumors ever come up at any meetings of 1 andtbatwasit 

2 the social office? 2 Q Do you know his home number? 

3 A No. 3 A 1 don’t. 

4 Q Now, did Mr. Withrow ever discuss with you after 4 Q Have you ever called him at home? 

5 thenightofthatchristonaspartyanythingahoutwhathad 5 A Once. WhenIwasanintem. Mysupervisorhad 

6 happened that night? 6 askcdmetogetaholdofhimbecause~hadsomeaisiswitl 

7 A ~~~~brok~~J~~of~s~- 7 an eve& and WC paged him unsuccessfully and.then we +ked 

8 Iwasonvacation@entbestorybroke,Iwascmahvo-week 8 the switchboard to-put us through to his home. 

9 vaeatk wknIcamcback.bccameuptomyofthatsamc 9 Q Okay. Did the subject of Monica come up at all? 

0 point,Idon’tlolowifitwasthe&ythatI~or 0 A No. 

1 savetaldayslater,andsortofaskedmwhatIthought, I 1 Q You were in&n&wed by FBI agents who work for the: 

2 wasindifferent 2 Offke of the Independent Counsel on 0~ aboutppril 8th of> 

3 ~d~rn~~~f~ ~~f~~t1~ 3 1998. 

4 fsleaEdbaininDecemberandheaskedifIwasgoingtobe 4 A hkkhmm. 

5 okay. And I said no one said anything to me, Capricia hasn’t 5 Q J.&s that sound right? 

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A Yes. I don’t remember the exact date, but, yes, 

WaS. 

Q Rid you talk to Mr. Withrow or attempt to call him 

either before or after that interview? 

A I was instructed by my attorney that I shouldn’t 

talking to anybody from rhe White House that would have been 

remotely involved or, you know, sort of -- somebody that 

would be involved in tk investigation, I guess, is the best 

way to put it. And that would include him. 

Q Okay. So you did not call Mr. Withrow either 

before or after you were interviewed by the FBI agents 

A Well, the conversation that I had after I left 

the White House but before the interview with the FBI agent 

was obviously a conversation that I bad, but once I wz 

notified that I was going to be intaviewed by the FBI and I 

retained an attorney, my attorney then advised me that 

conversations like that should cease until we figure ou 

what -- 

BY MR. WISENBERG: 

Q But did you try to call him anyway? 

A No. I called the White House. Yes, I did, but I 

didn’t talk to him. 

BY Ms. WIRl-Hz 

Q When you say you called the White House, was that 

after your attorney advised you not to speak to anybody? 

Page : 

A I called the White House after my attorney advir 

mRnottospeaktoanybodyandItoldhimthatIwascallinl 

the White House because as I already stated I’m unemploye 

and so Capricia had offered to do letters of recommendation 

for me and things of that nature and so I was calling tc 

followupbecauseI~‘tnceivedtheminthemailyefas 

I was told that I was going to, and that’s why I called And 

X~ldhim,myattoraey,~beingmyattomey,thatIwas 

going to do that 

Q Okay. And did you get your letters of 

recommendation? 

A Yes, Ive ’ received lhzm since. 

Q Now, can you tell us what number at the White 

House you called when you spoke to Bryant Withrow! 

A As I had mentioned, I called -- I believe I 

called 456-7136, which is the main number to the soci 

office. However, I might have called somebody’s 

direct extension, I can’t remember, and then had them 

transfer me down. 

Q Okay. You did have a conversation with Office] 

Withrow at that time. 

A Yes. 

Q And tell us again what you discussed during thal 

conversation, everything that you could remember. 

A Just basic -- what are you up to, nothing, what a 

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Page 35 

you up to, how’s work, fine, busy, are you aU settled into 

your apartment, yeah, it’s getting there. Something of that 

nature. What’s going on with you, same old same old. 

was about it. “c 

Q What about Mr. Fritch? When is the last time yet 

spoke to him? 

A November of ‘96. I’m sorry, correction. The last 

time I talkked to him sort of extensively was November of ‘96. 

When he heard that 1 got promoted to the social office ir 

April of ‘97, be. stopped by, said hello, and that was about 

it. He was in the building. He had been transferred to some 

place off compound. 

Q Have you ever had any conversations with Jeff 

Bowman, who you mentioned before is a uniformed Secret 

Service officer, about a story of an incident that happened 

at the n&-&west gate of the White House? 

A yes. 

Q Can you tell the grand jury about that? 

A Sure. Jeff told me this story, on or about January 

or February of this year, I’m guessing to say it was February 

since I was on vacation the last two weeks of January, and he 

had titd me that a friend of his who was posted at the 

northwest ga@ a uniformed off& that was poste~I at the 

northwfftgate,hhadsomesortofnmin,Iguessistbebest 

way to put it 

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Monica had come to the gate, she was cleared in, 1 

don‘t know who cleared her in, but the offtcer, tbc procedure 

as I understand it, and we all go through it, as staff 

membasiswtKayouclearsomebodyinaadthcyannetoth 

gate,theyYhOWlDtoSecretService,theygOthnwghametal 

detector and their bags are checked if they have any, ani 

then Service will call the individual that cleared them in 

and say your guest% here. 

At that point, the staff member will say, okay, 

couldyousatdthmuptothel~~yorcwldyausndthan 

tothereceptionroomorwhatnot. Andthat’swhattakcs 

place. 

When this particular story was told to me, Jeff 

said that his friend had witnessed her coming into the 

northwest gate and, you know, they’re doing their no& 

procedure and the officer caLled up to wbaevez cleared her in 

and said, “Your guest is here,” and she said, you know, “It 

will be a few minutes, could you send her to the lobby.“ 

And the officer that called had hung up the phone 

and apparently had said something to Monica to the nature of, 

you know, “YOU’IC going to have to take a number,” “You’r 

going to have to wait in line,” you know, 7here’s someone 

else in with him.” 

I assumed when Jeff told G-that story that him 

meant the President. Most of the President’s guests ate 

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Grand Jurv Proceedings Multi-PilgCW May 19,1998 

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Page 41 

cl& in through the northwest gate. Also, when you clear 

a guest in, you put in on the computer or if you do it over 

the phone who they’re going to visit. So that’s why I 

assumed that. I didn’t ask Jeff for clarification. 

So apparently Monica had got in and u%en she had 

umversed with the President, she had me&& the comment 

that the officer had made. 

Allegedly, the President got very agitated at 

this, asked tn speak to the Secret Service officer in charge 

or on duty that day for that shift, brought them to the Oval 

and had words with them ahout their hehaviu towards his 

Q Whenyousaythesqwasitwiththesupervisorand 

with the officer? 

A It was -- bz - now, it’s unclear to me. I took it 

to be he asked for the supervisor on duty, he got the 

supervisor for that shift 

Q A sergeant? 

A I believe it would be a sergeant. It could be 

lieutenant, but, again, I don’t know. And tbeo when he asked 

thispCXsonwhobewas,hesaid,“Idon’twantyoyIwant 

your boss.’ And so that’s when this other, I guss higher 

mnl&qStzai5tServiceoff~cialwassummonedtotheOvalas 

well. 

Q Do you how the names of either the sergeant, if il 

Page 42 

I was a sergeant, and the sergeant’s supervisor? 

2 A I didn’t ask Jeff and I’m unclear who was on duty 

3 that&y. TbehierarchyoftbeSecret!?ervicesutofeludes 

4 meonaeyou--youknow,getinwiththeraalcssoIdoa’t 

sknow. 

6 Q Okay. And did Off&r Bowman tell you who the 

7 PIl;sidcot’ogrrstbadkntthatday~Mo5icaJndkcntoJd 

8 totakeanumberortowahinline? 

9 A Eleanor Mondile. 

0 MS. WIRTHZ I think at this time were ’ going to ask 

J you to stg, outside for a few minutes. 

2 THJZ WITM~SS: Okay. 

3 Ms. WJRTH: Thank you 

4 hut_ WIsmBERG: We will come gel you in a couple 

5 minutes. 

6 THE- Okay. Shouldlgooubackoutwhem 

7 Iwas? 

8 MS. WXRTJJ:;_NO, just step outside the door. 

9 MR. WJSENBERG: You can go out to where your 

0 attorney was. Yes. 

J THE WIMESS: Okay. 

2 (Witness excused. Witness recalled.) 

3 MR. WTSENBERG: Let the record reflect that the 

4 witn~ has reentered the grand jury room. 

5 Madam Foreperson, do we still have a quorum? 

Page 43 

1 THE FOREPERSON: Yes, we do. 

2 MR. WISENBERG: Are there any unauthorized persar,; 

3 present in the grand jury room? 

4 THE FORflPERSOZi: No, there are not. 

5 Ms. Schwartz, you’re still under oath. 

6 THE WIDIESS: I understand_ 

7 BY MS. WJRTH: 

8 Q Ms. Schwartz, if the WAVES records at the Whiz 

9 House indicated that you had mruie a request for the PZTZXXZ 

0 ofMonicaLRvinskyioth:WhitcHousconDacmber6,1997ruc 

J 

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6:OO pm. for the purposes of seeing the President, could ya 

explain that to the grand jury? 

A Sure. Whenwedoaguestlistforthesocial 

office, to go through WAVES and to get the appropriate 

security clearance, it’s dm: over a computer because there 

aresemanynamesit’stoomuchtodoovertbephooe. ArJ 

when~dotftat,thepasonwhois~requestororthe~ 

member, it goes through their terminal, so it has their name 

assigned to it 

We also have to put in the principal that they’re 

visiting, the principal being the President, First Lady, 

Vice President or Mrs. Ciore. And you always have to put 

the highest ranking principal that they’re going to visit 

because of the level of security clearance necessary for all 

of them. 

So even though this was a presidential and 

Page 3 

First Lady event, the Pr&deat would be the highest rank& 

so his name would go in to visit with or visiting, under 

that category. So it would be my name, then visiting ttx 

PresideatandthentbetinzoFtheeventortheapproximate 

timeoftheevent. 

AJUROR: Wastheeventthe%horthe6th? 

THE WlTIGSs: I couldn’t recall the date. It was 

the5thuthe6th. IknewitwasthebcginningofDcamba, 

but not the 4th. 

BY MR. WISENBERG: 

Q Let me just tell you that our information is that 

theeventwasthe5th. Asamatteroffact_weknowtht 

eventwasthe5tb. ~y~~l~~~to~in 

the day after that? 

A No. 

Q Is it possible that on the 5th or some time before 

the 5th you could have scheduled her for the 6th? 

A Ibconlywaythattbalcouldbe-endrdon’tknowif you have the U number to that particular WAVES 

appointment. Each WAVES appoimmt has a U number ass+ed 

by Secret Service. It’s their identification code. 

The only way I would think that that could happez 

isif_becaw:foraparticularevd;tthcl_eare400or500 

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Secret Service because it inundates the system and it 

sometimes can cause the system to crash, which has happenec 

to me before. 

So I start sometimes 48 hours in advance or 72 

hours in advance sending the portions of the lists that I 

have complete. It is possible that in sending them I entered 

the wTong date and it went that way and was cleared for that 

date. 

I don’t have a recollection of that, I don’t have 

knowledge of remembering doing that. It does happen. 

Christmas is a busy time. It certainly could have happened 

that the keystroke went to the 6th instead of the 5th. 

Q But you don’t remember waving monica in the day 

after this party. 

A No. Certainly not. 

Q And that would be something you would probably 

remember, right? 

A Absolutely. Especialiy if it was just waving her 

in by herself. I would never be asked to do something like 

that 

Q Did you ever see Capricia Marshall talking to 

Vernon Jordan on the phone? 

A Then or at any time? 

Q Any time during the time you worked there at the 

social office. 

Multi-PagP May 19,1998 

5 Page 17 

1 A Okay. 

1 2 A JUROR: Could anybody sit at your computer 

3 terminal if you left it on without shutting it down an 

4 rWpe.St a WAVE? 

5 THE mESS: Yes. 

6 BY MR. WISENBERG: 

7 Q Using your name? 

8 A If I was logged in to my tennina as me, and tile 

9 reasonI’msayingasmeisbecauseifmyterminalisoffand 

11 0 UMXI booted up, you have a password prompt and a oame pnxqq 

I 1 soifIwasloggedintomyfenninafasmeandleftit 

12 ’ unatta&S, wbcoevu anybody would put in a mq~~~t, it would 

1. 3 autotnaticaBy come up aa me because it’s pmgmmmed with my 

Id 4 name under my password. 

1: 5 Q Does anyone have your password to get into your 

f II 6 computer? 

I’ 7 A No. Not to my knowledge. 

11 B Q Okay. Because wt: have an entry for you on the 6th 

l! 3 Either it could bc a mistake, that you keyed it in wrong 

21 3 or -- 

2. I A That I was logged onto my terminal? Or that - 

2: 2 Q That you maybe had been logged on on Friday mc 

2: 3 didn’t log off and someone used that to log her in on tlx 

2’ 1 6th. 

21 5 A Right. 1 often - especially in ISecember, i workf 

i pageI weekends, so I often did not log off from my terminal a 

; 

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Page 46 

A I saw Capricia on the phone a lot. I never knew 

whoshewasonthephonewith. 

Q All right_ It wouldn’t surprise you if she talked 

to Vernon Jordan on the phone. 

A No. It wouldn’t surprise me. 

Q Because you said you saw them talking, they 

appearedtobefriends. Isthatcormct? 

A Absolutely. But I was not in Capricia’s dimct 

suite of offices. I didn’t answer her line, so I really 

could not speak to any knowiedge of knowing who’s on her 

line. 

Q If Monica Lewinsky came unscheduled to one of the 

gates on a par-tie&u day and a Secret Service agent doing 

his jab, an officer, he would say, ‘@You’re not on the list to 

get in.” 

A Absolutely. 

Q ~uld~~~y~d~t~put~~t~ 

and then allow her to get in right then? 

A Absolutely. Secret Service would have to call a 

staff member and a staff member would have to clear ha in. 

Q And that didn’t happen to you on the day after the 

Party? 

! night, I just locked my office door. 

I Q That’s a breach of security, isn’t it? 

I A It is a breach of security. But once we got out 

i ofan~tatmidni&tandIwastimdandallI~talto 

i ~~go~I~~‘t~t~sit~d~tfor~ 

’ computer,knowingIwouldbeinatsomepointtknextday. 

I I don’t haveiecollection if I did work on the 

~6thorifIdeeidedtoworko11the7th Iusuallyehoseamz 

I &ya~~go~~dw~~it~~~b~ Ibe 

lockoomydoorHasnotasec~one,soEmybodycould~ 

! in. 

A Not the day after, no. I thought the day after was 

a Saturday, but I don’t know. 

Q It was. 

1 A JURORz ti even though you left on your m&be, 

b so you’re saying if you left your door open and your mad&e 

S wason,sa&odycouldjust~in? Youdon’thwcas saver password where you could lock the screen? 

I miEwllMss: ~~y~itl~~~y~ _ 

I A JURORZ But, you know, lock the screen on hoId 

3 wben3youcan’tgetinatal.l. 

1 THEWITNEE& No. Imean,ithasafunctionthat 

I youeandothat. Ineverdidthat Ineverusedit 

! h4R. WISENBERG: Going once, going twice? 

I May the witness be excused? 

I THE FOREPERSON: Yes, she-may. 

i TKE WITNESS: Thank you very much 

Diversified Rc~orting Scxvices. Inc. (202) 296-2929 

Page 45 - Page 48 

_ 
3547 

In re: Grand Jury Proceedings Multi-Pagt? 

Page 4 

May 19,1998 

1 MR. WLSENBERG: We’ll see you Thursday. 

2 Just kidding. 

3 (Laughter.) 

4 MR. WISENBERG: Thank you very much. 

5 'IHE wllmss: Am I done now? I don‘t have to come 

6 back tomorrow? 

7 MR. WISENBERG: You’re done. 

8 m FOREPERSON: You're done. You are excused. 

9 Gohome. 

0 

1 

2 

3 

4 you. 

5 

6 

7 

8 

MR. WISENBERG: Unless we call you. Yes. 

mm=: Okay. 

MR. WKENBERG: You’d better get out of here fas 

m WITNESS: Don’t follow me out the door. m 

MR. WISENBERG: Thank you 

THJZ FOREPJZRSOM Thankyou. 

(l'hzwitness was excused.) 

(Whfzeupoq at 455 p.m., tfre taking of testimony 

9 inthepsesenceofafullquoru.moftheGrandJurywas 

o concluded.) 

1 +**** 
3548 
3549 

Mull 

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PROCEEDINGS 

whereupon, 

hfAR!xAsanr 

wasadledasawituessaud,afterbaviugbeurdulyswemby 

t&FompemonoftbeGrandJuiy,wasexamuudandtestifll 

as fol.lows: 

EXAMlNATION 

BY MR. EhWICKz 

Q ~ynameisMikeEmmlck. I’mwitbtbeOffieeof 

Iudepe&ntCeunsclandwbatI’dllketedofirstistostt 

fortl&aswedoroutinelyintIle5emattas,eertainofyour 

rigbtsandobligaticmsasyouappearbereasawitnessbefore 

the grandjury. 

Letmefirstaskyou,didyouappearherepursuant 

to a subpoena? 

A Yes. 

Q Allright. Andyouunderstandthatweare 

conducting here an investigation an investigation into 

suspected fedeaal viola&s in cenne&m with eonduet by 

h&lica LWinsky and otben, sllspectod pajury, obshuctioo of 

1 justice and related matters pcrtainin~ to witnesses in tk 

2 PaulaJoncscase. IlAatisiugeneraltermstbenatureoft.be 

3 inv~onwe’reconducting. Do you-that? 

4 A yes. 

5 Q You have a couple of rights and obligations that 

.A 

Pagem March 19,1998 

1 

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I’ll explain to you here. One is the right to consult with 

your attorney. Do you understand what that right is? 

I believe so. 

All right. Do you have an attorney with you? 

Yes, I do. 

Who is that? 

Stuart Pierson. 

And is he outside the grand jury room? 

Yes. 

All right. Do you understand that if you would 

liketoconsultwithhimatanytime,justsaytomeorsay 

to the group at large that you’d like to take a short breal 

and we’ll do that consultation. 

A ‘Ihankyou. 

Q-You also have a Fifth Amendment right and that i 

a right not to be wmpelled to answer any qwstions that 

may incriminate you Da you unhstand wbat that right is? 

A Yes. 

Q And if you should feel Sony need to ask your 

attomey about wbetbez you need to invoke that right, you 

can simply ask again and we’ll allow you to do that 

consultation. Is that clear? 

A I believe so. 

Q Okay. You also have an obligation and that is an 

obligation to tell the truth. That obligation is imposed 011 

1 

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youbecauseyouhavetakenanoath. Asaresultofthat 

ea&anytimetbatyoumakea staumaitbemintbegtiuid 

jury that is an intentionally false statement, that could 

exposeyoutopromcutionfefperjury. Pajutyisafedaal 

fdoaytbatbasafivGyearmaximumlam. Doyeu~ 

that? 

A IbelieVe%. 

Q A.llright. Doyouhaveanyquestionsabouteither 

tbepmomdingbemurtbeprocedunbefomweproceedtoask 

questions? 

A Just who’s at the table? Who’s quedioning and 

who’s here? 

Q Theseamtwograndjurors. Thisisacowt 

repor&. MynamcisMikeEmmiek I’mwitb~QfEceof 

Indepeadmt Ceuusel. Ibis is Sol wiscnbag. He’s alsu with 

the Qfllce of Indepen&mt Counsel The rest of the people 

here are also grand jurors. 

A Okay. 

Q Any other questions you might have? 

A-Idon’tthinkso. I’llaskthzrnifIgetconfttsed. 

Q Allright. Fairenough. WhatI’dlktodofiist 

is just ask you some backgroundquestioas. I say background 

3 questionsbccauscalthoughI~wtbatyoullavc~ 

4 baekgruuud kinds of questions before in other grand juries 

5 andothcrsettings,thisgrandjuryhasn’thadthcbarefitof 
3550 

Page 5 

1 hearing what, for example, your educational background is or 

2 your work-related ha&ground prior to coming to the White 

3 House. So let me stat? off with your educational backgrcund. 

4 A I graduated from the University of California in 

5 Santa Cruz with a degree in sociology. 

6 Q And when would that have been? 

7 A 1990. I was a m-entry student. Ran a business at 

8 the time, put myself back through school through a women’s 

9 -try program. 

0 Q And what about your occupational program? 

1 A What do you mean? 

2 Q What jobs have you had prior to coming to the White 

3 House? 

4 A IranabusincssofmyownthatIstarted I 

s was an interior designer for 14 years. I had a home 

6 mrnodel/constru&m business that I started and ran for 

7 three years. Prior to that, I had been a Headstart teacher 

8 and Homestart teacher and worked in various recreation 

9 Programs. 

10 Q All right_ How did you come to work for the White 

:I House? 

12 A I’ve known President Clinton since I was 19 and 

3 since I’m 50 now, that makes it 31 years. 

:4 Q Soyoug.mwupwithhim,inpart,inArkansas? 

:5 A Inpart 

Page6 

Multi-Pagem March 19,1998 4 

, pw7l 

I President in whatever form they come in and then those 

2 messages that go out to the general public. I 

3 I always said that we were the largest outreach 

4 office because we were the office that the ordinary citizen 

5 inwantingtotalktothePresident,that’swheretheywere 

6 able to interface with him and I oversaw all the differen 

7 divisions of that from a children’s division that we had all 

8 the way to the phone and messaging and messages and letters 

9 and faxes and e-mail and all of that. 

1 0 Q Andasthedirector,youwerethcheadofthe 

I 1 entire section? Or is it a division or - 

1 2 A Its ’ department. 

1 3 Q Department? 

1 4 A Y__cs. 

1 5 Q All right. All right. And how long did you hold 

1 6 that position? 

1 7 A Officially, I don’t know. And you’ve probably got 

1 8 thoserecords. Ithinkitwasaboutayearandahalf. 

1 9 Q All right. And when you left that position, what 

2 :O new position did you take? 

2 :1 A I went to the Office of Public Liaison. I’ve 

2 :2 l-etcxdauthewaythroughthesametitlejwhichisDeputy 

2 :3 Assistant to the President. In the OfEce of Public Liaison, 

2 :4 I did mom specific constituency outreach. I developed 

2 :5 umstituencyouneachplansandIwas-forabout-Ithink 

, Pagec 

1 aboutaytari.nthue,Iclidoutreachtctbtgayandlesbiaa 

2 cormunity. 

3 Q Were you then the director of the Public Liaison 

4 section or the Public Liaison department? 

5 A No. AlexisHermanwasthedimctorofthat 

6 wt_ Iwasqpeofthedeputk. And~bckvcunhad 

7 two c&n&s. Thats ’ pretty typical of each department 

8 having ome director, two deputies. 

9 Q Wh~~replaccdyouinthc~~tioru~ucsragcS 

1 0 seJctionwimlyouleftthere? 

1 1 A Jim Do&in, I believe. 

1 2 Q YouwereinthePublicLiaisondqartmmtforabout 

1 3 how long, did you say? 

1 4 A Roughly, a year. A little over a year. 

1 5 Q AIlright. Andthenwheredidyougoto? 

I 6 A Then1wenttoPoliticalAffairsandIwasoneaf 

1 7 the deputy dkctms in Political Atxlira And in Political 

1 8 Affairs, I did more supervisory capacity of looking at al 

1 9 tkekctions. That’s.theoneoffiiatheWhiteHousethat 

2 0 acmallytracksal.ltipoliticalactivitiesthatare 

2 1 occur+gonthePmsident!sbehalfandalsoinallthe.C” 

2 2 statesandIworkedwitha~ofBcopleinthatofficcjusl 

2 3 tracking all those different state activities. 

2 4 Q About how many employees would there have b&n in I 

2 5 the Political Affairs denartment? I 

1 Q And did you work at all in the campaign, the ‘92 

2 campaign? 

3 A Yes. I ran the campaign in California with John 

4 Emerson. Iwasthefieldax&natorintheprimatyin’ 92 

5 andthenIranmntbanCalifomiaforClintcm-Gomin’92. 

6 Q Afterthixtsuccessful campaigqwhatledyouto 

7 work in the White House? 

8 A IwasaskedtogobacktoLittleRockrightafter 

9 tbecampaigntoworkcmthe axnomiccxmfkaccanciwhile 

0 wofkingwthe aalomiccozlfam~tkRcsidalt~kaimeif 

1 IwoubIcomctoW~andworkir~thcWhitcHouscand 

2 I’vebeenhereeversince. 

3 Q Thats ’ a natural transition for me to ask about the 

4 positionsthatyou’vehadintheWbiteHouse. Ifycucould 

5 explain what posit.icQ!r you had$ approxilnately how long you 

6 heldthoscpositionsandwhatingeneralyourdutiesand 

7 msponsibiIities were there. 

8 A ThefirstjobthatIhadintheWhitcHousewas 

9 DimctorofCoxm.nunicationsandMessagesandthatwasa 

0 depar&nt-adually,whenwecamein,Ithinkthatwasthe 

1 kgcstdcpartmmtintkWhitcHousc. Wehadl2@artmmts 

2 witiit. 

3 I think historically it had had anywhere from130 

4 to probably 160 employees in it and primarily we were 

5 responsible for all of the messages that come in to the 

. I 

.Y -Tl n 
Tripp, Linda, , _ 

From: Lewinskv. Monica. ._ 

To: 

Subject: 

Date: 

Tripp, Linda, ,e 

RE: coffee break 

Tuesday, March 04,1997 1:21 PM 

believe me it is not that funny. just not a good idea to e-mail it. hope to c u 18r.msl 

From: Tripp, Linda, , 

To: Lewinsky, Moni 

Subject: RE: coffee break 

Date: Tuesday, March 04, 1997 1:18PM 

Unfair to make me wait. However, I may be able to get out of here around 3 or so, I really need a break. Ill ’ let 

you know. 

--____---- 

From: Lewinsky, Monica, ,w 

To: Tripp, Linda, , OSD/PA 

Subject: coffee break 

Date: Tuesday, March 04,1997 12:54PM 

Priority: High 

hi. its ’ me your loyal freak. i forgot to tell you something mildly amusing...mildly. maybe we can escape for coffee 

later? does your sched permit? (VII tell you the funny then) msl 

845-DC-00000055 

Page 1 
3852 

From: Lewinsky, Monica, , OSD/PA 

To: Tripp, Linda, , OSD/PA 

Subject: hi, ya 

Date: Wednesday, March 051997 10:05AM 

Priority: High 

Oh, well. w should (if Betty 

is nice) get my tie today. I sure hope he like s it. make me feel better and tell me its ‘ really pretty, o.k.? msl 

84%DC-ooooo056 

Page 1 
3853 

Tripp, Linda, , a 

From: Lewinsky, Monica, , _ 

To: Tripp, Linda, , r 

Subject: RE: hi, ya 

Date: Wednesday, March 051997 11:47AM 

Remind me to come to you when i feel good more often (ha-ha-ha)! In fact, maybe if i come bug you later youll ’

. . make me feel better about looking so GROSS today. The highlight of my appearance today being the _ I 

have on my cheek. Hmmm...attractive! Im ’ bored. Would you like to go for coffee later? I know youre ’ busy these 

days so I wont ’ be offended if you cant. ’ buh-bye msl 

From: Tripp, Linda, ,a 

To: Lewinsky, Monica, ,_ 

Subject: RE: hi, ya 

Date: Wednesday, March 05.1997 11:34AM 

Are you asking me if the tie if really pretty? It is positively gorgeous. I am knot (ha!) particularly into ties, but from 

my exposure to you, I am developing an interest. Yours was stupendous, no kidding, clean, crisp, texture, color, 

pattern, bright, without being at all over the top.....a total hit. 

From: Lewinsky. Monica, ,e 

To: Tripp, Linda, , ( 

Subject: hi, ya 

Date: Wednesday, March 051997 10:05AM 

Priority: High 

n. Oh, well. _ should (if Betty 

is nice) get my tie today. I sure hope he like s it. make me feel better and tell me its ’ really pretty, o.k.? msl 

Page 1 
3854 

Tripp, Linda, , _ 

From: Lewinsky, Monica, , __ 

To: Tripp, Linda, , _ 

Subject: howdy 

Date: Thursday, March 06,1997 9:24AM 

Priority: High 

Hi, there. o.k. stupid point to make but i figured out that the he Betty did call on V-Day because her bosbwas in 

NY on Tuesday, the other day I was out of town. 

its ’ sweet. 

Unless of course, she called Thursday evening here. But still, 

I guess I would have seen him on V-Day. Oh, I also wanted to tell you about thetie thing.... he didn;t 

wear the tie I sent him for his B-day for, i think, three weeks. so well ’ see. whats ’ your day like? msl 

84%DC-00000058 

Page 1 
3855 

Tripp, Linda, , q 

From: Lewinsky, Monica, _ m 

To: Tripp, Linda, ,- ‘

Subject: momin’ 

Date: Tuesday, March 11.1997 8:l OAM 

Priority: High 

O.K. Sol got your letters that came in to Mr. B at 5:lS pm signed last night! Id ’ say you owe me, but its ’ more like 

Im ’ paying you back! Id ’ love to have lunch if you can today. Lots ’ to kibbii about. (well, nothing too interesting). 

im ’ so annoyed that i dont ’ know if- is comin’ home or not tonight. Oh, well, maybe it’ better if i dont ’

know. WRITE BACK. msl 

Page 1 
3856 

Tripp, Linda, , _ 

From: Lewinsky, Monica 

To: Tripp, Linda, , aSubject: letter 

Date: Monday, June 23,1997 1:17PM 

Priority: High 

<<File Attachment: doc2.doo> 

845DcMx)o60 

Page 1 
3857 

Clifford H. Bemath _ 

i i 

Principal Deputy Assistant Secrhry of Defense 

(Public Affaits) ’ 

Mr. Clifford H. Bemath has been serving 

as Principal Deputy Assistant Secretary 

of Defense for Public Affairs since 

March 1993. 

He served in the United States Army for 

21 years in a variety of stateside and 

overseas assignments including a tour as 

an Infantry officer in Vietnam, command 

of an Infantry and a Basic Training 

company, Executive Editor of “Soldiers” 

magazine, and in the Office of the 

Assistant Secretary Defense for Public 

Affairs. 

He has written a book and published 

more than 70 articles on military-related 

topics and issues. 

In addition to his responsibility for the 

day-to-day operation and management of 

the Office of the Assistant Secretary of 

Defense for Public Affairs, Mr. Bemath 

is the senior Public Affairs planner for 

media coverage of military exercises and 

combat operations and oversees the 

operation and deployment of the DOD 

National Media Pool. He is responsible 

for establishing public affairs policy and 

doctrine for the Department of Defense. 

He is also responsible for a major 

Partnership for Peace initiative to help 

those nations improve relationships and 

communications between their media and 

their Defense organizations. 

Mr. Bemath oversees the operation and 

development of “DefenseLINK,” the 

Department of Defense home page for 

release of imagery and information about 

the Department via the intemet. 

Mr. Bemath holds a Bachelor of Arts 

degree in English from the University of 

Missouri, and a Master of Science degree 

in Journalism and Mass Communications 

from Kansas State University. He is a 

graduate of the Defense Information 

School, the Armed Forces Staff College 

and the Federal Executive Institute. 

Mr. Bemath is from St. Louis, Missouri. 

He lives in Virginia, with his wife, Beth. 

They have two sons, Dan and Tom. 

845DC-oooooo61 
3858 

Tripp, Linda, ,m 

From: Lewinsky, Monica, , m 

To: Tripp, Linda, -4 

Subject: bye 

Date: Wednesday, December 24,1997 1:38PM 

LRTI will miss working with you tremendously! Who will edit my letters? Who will tell me my grammar stinks??? Who 

will escape for coffee breaks with me? 

Well ’ only be a phone call away! I think the world of you and know everything will work out great!!! I cant ’ wait to 

see how skinny you get! You go girl!!! 

All my love, 

MSL 

845DC-00000062 

Page 1 
3859 

ASSISTANT TO T)-(E SECRtTARY OF DEFENSE 

1400 OEFENSE PENTAGON 

WASHINGTON. O.C. 20301-l 4Oo 

CVBVC AFFAIRS osMAf?1996 

Honorable Strom Thurmond 

Chairman, Committee on Axmed Services 

United States Senate 

Washington, DC 20510-6050 

Dear Senator Thurmond: 

This is in response to your letter posing a series of 

questions concerning the Office of the Assistant to the Secretary 

of Defense for Public Affairs. YOUr questions and my responses 

are set forth below. 

Question l- From your service as an Assistant to the Secretary of 

Defense for Public Affairs, what do you consider to be the most 

serious problems in the management and operation of the public . 

affairs activities of the Department of Defense? What management 

activities and timetables would you establish to address these 

problems? 

Answer 1. The office has two primary missions: to provide timely 

and accurate information about the activities of the Department of 

Defense to the media and to the American public and to help keep 

the men and women in the U.S. military informed. I have not 

identified any serious management problems that affect our ability 

to accomplish these missions. Still, there are always management 

challenges. 

One of my concerns is how to get more and better quality 

photography and video imagery from military operations and 

exercises. The Department deploys combat photographers to 

document these activities, but we need to do a better job of 

training these photographers, defining their missions, clearing 

imagery for release, and centralizing the storage and distribution 

of that image-T. My staff met in January with senior military 

public affairs officers to discuss these problems. I have asked my 

principal deputy to lead this project. He plans to have specific 

oversight and policy recommendations to the Services and the Joint 

Staff in the next few months. 

Another challenge is how to cope with the rising demand for 

documents under the Freedom of Information Act and Mandatory 

Declassification Review. We are looking at a range of management 

steps that will enable us to provide timely service within staff 

limits. Among those are reorganizations and reallocation of 

assets, and technology enhancements, such as bar code scanning, to _ 

reduce some of the manpower-intensive aspects of the FOX-and 

security review processes. 
; 

3860 

Question 2. why is it'important to you to be an "Assistant 

Secretary of Defense" rather than an "Assistant to the Secretary 

of Defense"? 

Answer 2. The senior spokesman for the Department of Defense must 

have the stature and authority to set and enforce the principles 

of openness, accuracy, and timeliness in providing information to 

the public and the media. When this position was downgraded from 

an Assistant Secretary of Defense in 1993, the Pentagon press 

corps voiced concern about possible reduced access to the 

Secretary and other leaders. I enjoy an excellent working 

relationship with Secretary Perry,.his senior staff and the Joint 

Staff, but this relationship is personality-based. Elevating the 

job by making it subject to Senate confirmation would strengthen 

the public affairs function in two ways. First, it would 

institutionalize necessary access to senior civilian and military 

leadership. Second, it would make it easier for me and my 

successors to represent the Department in dealings with other 

government agencies and with foreign governments. 

Question 3. Should you be confirmed as Assistant Secretary of 

Defense for Public Affairs, what would you view as your princi&{ 

responsibilities to the Secretary of Defense? 

Answer 3. My princisk responsibility is to help the Secretary 

and the defense leadership keep the public informed about the 

activities of the Department. I will continue to make as much 

information as possible available to 'the public and to our Armed 

Forces, constrained only by operational and intelligence needs and 

statutes such as the Privacy Act of 1974. 

Question 4. How would you describe your access to Secretary 

Perry? How often do you see him and what activities are you 

routinely included in? 

Answer 4. My access to Secretary Perry is excellent and extensive. 

I usually see him several times,a day, both in regular meetings 

and as-needed. I generally brief him before every dealing with the 

press. Last year he talked to the press 173 times in the United 

States and more than 130 times on foreign trips. A direct 

telephone line links our desks, making communication quick and 

easy. 

845-DG-0000a)64 
3861 

Question 5. DoD directives provide 

a free flow of news and information 

-_ 

that the ASD(PA) shall "ensure 

to the media, appropriate 

forums, and the American people limited only by national security 

constraints and statutory mandates." What guidelines would you 

use to determine what information can and cannot be released to 

the news media and the public? 

Answer 5. I will continue to ensure that the release of 

information is consistent with the provisions of applicable 

statutes, executive orders and Department of Defense directives 

and instructions. Our goal is to release all useful information, 

unless specifically exempted by law, national security 

requirements, or privacy considerations. 

Question 6. The ASD(PA) has responsibility for the security 

review of DOD materials for publication or public release, 

including testimony before congressional committees. What policy 

would you intend to follow in carrying out these responsibilities? 

Answer 6. I-intend to continue to use the procedures pre'scribed 

under executive order and to ensure that information will not be 

classified unless the disclosure could reasonably be expected to 

damage national security. 

Question 7. Aside from restrictions related to classified and 

sensitive source-related information, what restrictions, if any, 

would you apply in approving material prepared for publication by 

DOD personnel? 

Answer 7. In order to protect the Department and the author, our 

review should ensure that publication does not violate the law or 

codes of conduct. Our review should also ensure that the 

information published does not constitute, or even appear to _ 

constitute. a misuse of official information. 

Question 8. The ASD(PA) has responsibility for overseeing the 

provision of-news analysis and news clipping services for the 

Office of the Secretary of Defense, Joint Staff, and the Military 

Departments' headquarters. What policy would you intend to follow 

in providing this news analysis and in determining what news media 

reports should be disseminated throughout the DOD'S Washington 

headquarters? 

Answer 8. ‘The goal of our news clipping and broadcast transcript 

service is to give senior defense leaders an unvarnished selection. 

of international, national and community coverage of defense 

issues. I intend to continue this policy, which gives us the bad 

news with the good. This helps the department respond 

appropriately to public issues. 

845~DC-oooooO65 
3862 

L 845DC-OOOOOOM 

Question 9. Allegations of censorship and news management by 

military commanders of Stars and Stripes newspapers led to a 

requirement in the FY1988/89 Defense Authorization Act that the 

U.S. General Accounting Office (GAO) investigate the validity of 

these allegations. GAO reported that, according to a panel formed 

by the Society of Professional Journalists, evidence of censorship 

and inappropriate news management was conclusive at Stars and 

V 

es in the Pacific, but inconclusive for Stars and Strines in 

Nope. What do you believe is the role of the Stars and Stripes 

newspapers? Do you believe that the military chain of command 

should be allowed to interfere with, or influence the news content 

of the articles in these newspapers? 

- . 

Answer 9. The role of the Stars and Strioes is to provide an 

unbiased, free flow of news and information to military service 

members, DoD civilians, and their families, who are serving in the 

European and Pacific theaters. The newspapers help to: 

l Provide a free flow of news from the United States, 

l Foster a sense of community within the theater, . 

l Keep personnel educated and informed, thereby making them 

better service members, and better citizensThe military chain of command should not interfere with news 

coverage of the Stars and Strioes and should not attempt to 

influence the news content. 

These principles are reflected in the Department's internal * 

regulations governing Stars and Strrne s operations. . 

I believe that the steps taken since 1989 have strengthened the 

independence of the Stars and Strines and minimized the potential 

of undue command influence. 

Question 10. Do you believe that there is a need for an ombudsman 

to investigate and report independently to the Director of the 

American Forces Information Service or to the ASD(PA) on questions 

of censorship in the Stars and Strines newspapers? 

Answer 10. Yes, I believe the ombudsman to the Stars and Strines 

plays an essential, continuing role in maintaining the editorial 

integrity of the newspapers. 

The ombudsman position was created in 1990 in an effort to 

guarantee the editorial integrity of the newspaper. The three 

individuals who have held the position since then have been 
3863 

845DC-OOOOOO67 

seasoned professionals who were well known and respected in the 

journalism community. 

The ombudsmen have served as a vital safeguard. I know of no 

substantive allegations of censorship at the Stars and‘stripes 

while ombudsmen have been serving. The Ombudsman position should 

be continued. 

Question Il. What role do you currently play in monitoring the 

activities of the operations of'Stars and Strines and other 

service publications, and do you plan to change this role? 

Answer 11. As the principal advisor to the Secretary of Defense 

on public affairs matters, I direct the activities of the American 

Forces Information Se-ice (AFIS). AFIS exercises policy guidance 

and oversight of the Stars and Strloes, and military service 

command information publications. 

APIS also provides management assistance, and controls the 

disbursement of appropriated fund financial support to the Stars 

. and StrlpeS . This is particularly crucial at the present time, 

when Stars and Stripes faces severe financial problems in the wake 

of troop reductions and the transfer of the Stars and Strioes 

bookstores to the military exchanges. 

it should be noted that neither my office, nor AFIS exercise 

control over the editorial content of the Stars and Stripes. 

I do not anticipate changing my role or the current structure for 

overseeing the operations of the Stars and Strines and service 

command information publications. 

Question 3.2. If confirmed as ASD(PA), do you intend to employ the 

"pooling" arrangement that the Defense Department developed during 

Desert Shield/Desert Storm to permit selected members of the news 

media to accompany DOD operations? What, if any, modifications 

would you make td this process based on past experience and your 

own views? 

Answer 12. Whenever possible, I will continue to advocate free 

and open media coverage of military operations, as we are 

currently doing in Bosnia. However, when access to a military 

operation is not otherwise available to the totality of the media 

desiring coverage, the pool system has proven to be an acceptable 

alternative to the media and to military commanders. When pool 

coverage is required, I will continue to monitor the situation and 

ensure that the pool is as large as the operation will permit and 

is terminated in favor of free and open coverage as soon as the 

situation permits, as we did in Haiti. We work closely with news 

bureau chiefs and reporters to refine and improve pool operations. 

We have instituted regular meetings with the bureau chiefs and 

quarterly meetings for media "on call" for pools. We convene 

after-action meetings with the media after each deployment to 
3864 - 

845-DC-oooooo68 

discuss lessons learned and to 

also upgraded and standardized 

make needed modifications. 

our satellite and computer 

We have 

technology to mesh with the media's equipment. I will continue 

this trend of working closely with the media to improve pool 

operations and the overall relationship between the Department and 

the media. 

Question 13. Has the Department of Defense encountered any 

significant difficulties in recent years in the administration of 

the Freedom of Information Act or the access provisions of the 

Privacy Act? 

Answer 13. We have not yet encountered 

however, as indicated in my response to 

toward increased caseload and decreased 

problem could arise. We are attempting 

before it occurs. 

significant problems; 

Question 1, if the trend 

personnel continues, a 

to resolve this problem 

Question X4... What role, if any, do you _ - _ - . foresee for the ASD(PA) in 

the formulation and articulation of national defense policy? 

Answer 14. The ASD(PA) is charged with formulating policies to 

ensure a free flow of news and information to the public and the 

news media, consistent with national security requirements and 

other legal and regulatory requirements. 

anticipate direct participation in policy 

Defense spokesman, I do work closely with 

staff on the articulation of that policy. 

while i do not 

development, as the 

the Secretary and his 

Question 15. How many civilian employees and military personnel 

are assigned to the Office of the Assistant Secretary of Defense 

for Public Affairs? How is the Office organized? What other CjoD 

components does the Assistant Secretary oversee? 

Answer 151. 

a) The Office of the Assistant to the Secretary of Defense 

employs: ’ 

Civilian: 64 Military: 50 Total: 114 

b) See attachment for an organizational chart. 

c) The ATSD(PA) oversees the activities of the American Forces 

Information Service: 

American Forces Information Service (AFIS) 

Washington DC: Civilian: 94 Military: 50 

AFRTS/BC,CA: Civilian: a2 Military: 35 

DINFOS, MD: Civilian: 59 Military: 211 

Photo Sch, FL: Civilian: 12 Military: 87 

T-ASA, CA: Civilian: 132 Military: 10 

DVIS, MD: Civilian: 30 Military: 0 

AFIS Totals Civilian: 409 Military: 393 

Total: 144 

Total: 117 

Total: 270 

Total: 99 

Total: 142 

Total: 30 

Total: 802 
Question 16. Which management positions are occupied by civilians 

and which by military? What determines this breakout? 

Answer 16. As indicated on the organizational chart, the 

leadership of the Office of the Assistant to the Secretary of 

Defense for Public Affairs includes the ATSD(PA), who is a 

civilian; 3 deputies (2 civilians and one military); and 8 

directorates. Three of these directorates are headed by military 

personnel (Management, Defense Information, and Plans). The rest 

are headed by civilians. Thereeis no regulatory reason for 

designating a position as military or civilian. However, I believe 

that the deputy spokesman should be a military officer. 

Traditionally, the Directorates fqr Defense Information and plans 

have been led by military officers, and they are staffed primarily 

by military officers. 

Question 17. What percentage of public affairs management 

personnel are political appointees and what are their roles in the 

following areas? 

Answer 17. The OATSD(PA) has 2 non-career SES employees (counting 

myself) end 9 Schedule C employees. No such appointees are 

assigned to the American Forces Information Service. Assignment 

to the roles in question are: 

l Media Relations: 3 

l Public Relations: 3 

l . Information Dissemination: 4 

l Other (Administrative) 1' 

Question 18. What is the difference between directors and Deputy 

Assistant Secretaries? 

Answer 18f. As seen in the organizational chart, the Deputy 

Assistants to the Secretary work directly for the ATSD(PA), 

supervise and coordinate the overall activities of the individual 

directorates, and have broader responsibilities than the directors 

in establishing arid implementing policies and procedures. 

Question 19. What ability do directors have to make policy within 

the public affairs field? 

Answer 19. As the people who implement public affairs policy on a 

day-to-day basis, the directors are normally the first to 

determine when policy needs to be adjusted. Directors normally 

have a primary role in drafting new policies for coordination; 

however, overall PA policy is the responsibility of the ATSD(PA). 

Directors do have the authority to implement policies and 

procedures within their directorates to ensure efficient, 

effective and equitable operations. 

845-Ix3-oooooo69 
3866 

Question 20. Some believe you have 

organization. Do you agree, and if 

how do you plan to restructure? 

too many "layers" in your 

not, why not? If you agree, 

Answer 20. Our personnel strength has fallen from 126 people (72 

civilian; 54 military) in 1988 to 114 people now. By the end of 

FY 2001, we are scheduled to lose another 17 civilian slots. In 

response, we are streamlining the organization. We have already 

eliminated 2 deputy director positions and combined 2 directorates 

into one and eliminated the extra director position. 

Question 21. Usually at the end of a Presidential term, employees 

begin to -burrow in' to avoid losing their jobs during an 

administration change. Have you witnessed any of this recently 

within Public Affairs? Do you have a program for promotion from 

within this organization? (i.e. "upward mobility" similar to Army 

provisions). 

zulswer 21. I am not aware of any "burrowing in' from either this 

Administration or the previous one. All hiring and promotions 

within this organization are conducted in strict compliance with 

Civilian Personnel Regulations and are based on merit and 

qualifications. We provide pathways for upward mobility but do 

not make personnel decisions based solely on that factor. 

Question 22. Are you aware of anyone within the OSD/PA 

organization who received a senior level political appointment and 

then converted their employment to a career civil service 

position? 

Answer 22. No, however, I am aware of two instances that may 

appear to fall within the scope of this question. One involves 

one of my deputies, Clifford Bernath. He was a career civilian 

employee with the Office of the Assistant Secretary of Defense at 

the GS-15 level from August 1990 until August 1993. In March 

1993, he was asked by then ATSD(PA) Vernon Guidry to'assist in the 

transition to the new Administration. He was given a Limited Term 

Senior Executive'Service appointment to perform those duties in 

August 1993. 

In August 1994, Dennis Boxx, the Acting ATSD(PA), requested reestablishment of the position of Deputy ATSD(PA). The position 

was competitively recruited and advertised to "all qualified 

persons* for a 30-day period. Twenty-three candidates applied for 

the position. Two professional review panels reduced the list to 

six "Best Qualified" candidates and referred them to me for 

consideration. I interviewed them all and selected Mr. Bernath, 

based on his proven leadership, managerial, and technical skills. 

His career SES appointment was approved by the Office of Personnel 

Management Qualification Review Board in March 1995 and he was 

appointed to the position. 

845DC-oOOOOO70 
3867 

845-Dc-oooooo71 

The second case involves a deputy under the previous 

Administration, Robert Taylor. Mr. Taylor served under an SES 

noncareer appointment from December 1989 through June 27, 1993. 

Initially, he was appointed to the position of Deputy Assistant 

Secretary of Defense for Public Affairs- Upon leaving this 

position at the change of the Administration, Mr. Taylor was asked 

to serve intermittently as a consultant to the Special Assistant 

to the Secretary of Defense for Public Affairs. He was 

subsequently appointed to a career-conditional position based on 

merit competition, which included subsequent certification from 

the Office of Personnel Management, at the American Forces 

Information Service. 

Question 23. Please give us your philosophy on hiring practices 

and promotions within Public Affairs. 

Answer 23. As stated in my response to question 21, all hiring 

and promotions within this organization are conducted in strict 

compliance with Civilian Personnel Regulations and are based on 

merit and qualifications. I do not tolerate any favorable or 

unfavorable decisions made on the basis of race, gender, age or 

other factors which are unrelated to job performance and 

qualifications. I want my organization to be known as one in 

which qualified people can achieve notice and promotions. 

Question 24. What other public affairs offices exist in the 

Washington headquarters of the Department of Defense? What is the 

'relationship of the Assistant Secretaq of Defense for Public 

Affairs to each of these offices? 

Answer 24. Each of the Military Services (Army, Navy, Air Force 

and Marine Corps) has a public affairs office, as does the Office 

of the Chairman of the Joint Chiefs of Staff. In addition, 

several of the Defense Agencies have public affairs staffs: ’ 

Defense Contract Audit Agency, Defense Mapping Agency, Defense 

Finance and-Accounting Service, Defense Logistics Agency, Defense 

Nuclear Agency, and the On-site Inspection Agency. 

The Office of the Assistant to the Secretary of Defense for Public 

Affairs provides policy oversight and guidance to these activities 

in the areas of media relations, community relations, internal 

information, and Freedom of Information and Security Review. 

Question 25. The perception on Capitol Hill is that the number of 

news sources within DoD is increasing. Can you give us an idea of 

how many sources there were 10 years ago and how many there are 

now? If there is a substantial change, can you explain it? 

Answer 25, We work closely with the Defense Agencies, the Unified 

Commands and the Military Services, and those organizations have 

not changed significantly over the past 10 years. In fact, almost 

every organization's PA staff has decreased in size. My office 

does maintain some control over public affairs slots in OSD. 

Every request to establish a public affairs position must be 
3868 

. 

coordinated with my staff. Over the years, very few new requests 

have been approved. That said, due to the growth and demands of 

the media itself, many organizations have made one or more persons 

responsible for direct coordination with my staff on public 

affairs related matters. These people do not, however, serve as 

"media outlets" or as spokespersons and do not, normally, work 

public affairs as full-time duties. 

There have been substantial changes over the last ten years in how 

the news media cover the Department of Defense. Most importantly, 

the success of CNN has driven most national based news media into 

a 24 hour news cycle. This need for around the clock information, 

when coupled with the numerous technological advances available to 

the media, puts added pressure on the DoD to provide factual, 

coordinated responses as quickly as possible. The proliferation 

of trade journals and newsletters over the past ten years has also 

added to the public affairs challenge--there are many r&ore 

king for very detailed technical 

Question 26. Not long ago, you finished a *Joint Public Affairs 

Doctrine." When was it begun and finished? Who was it 

coordinated with? What lines of authority does it establish in a 

joint operation environment? What is the current status? 

Answer 26. Joint Publication l-07, "Doctrine for Public Affairs 

in Joint Operations," has not yet been completed. The prqject was 

begun in mid-1992 and took about a year to research and write. 

Since the doctrine would affect other wartime doctrine, both in 

all of the military services and with the Joint Staff, the 

coordination process for this doctrine has been extensive. It was 

formally !staffed within Service and CINC PA channels twice before 

it was ready for formal staffing at the Service Chief of Staff, 

Chairman Joint Chiefs of Staff and CINC level. It is now 

completing its third--and, I hope, last--staffing. The suspense 

to the Joint Staff is March 8, 1996. We expect publication within 

a few months from that date. 

The doctrine states that the ATSDfPA) "retains primary 

responsibility for the development and consistent implementation 

of DOD information policy" and lists the further responsibilities 

of this office. The doctrine also defines the responsibilities of 

the Joint Staff, the Military Services and the Combatant 

Commanders. 

Kenneth H_ Bacon 

Assistant to the Secretary of 

Defense for Public Affairs 
OFFICE OF THE JiSSlSTANT TO.THE 

SECRETARY OF DEFENSE (PUBLIC AFFAIRS) 

/ ASSISTANT TO THE 

SECRElARY OF 

DEFENSE FOR PUBLIC 

AFFAIRS 

Kometh H Bmon 

SECDEF PA 

(COMHUNICATIONS) 

Wflllmn B. Blacklow 

\ 

DIRECTORATE OmEcroRATBWR 

FOR PLANS UANMEYENT DEFEME INFORMATION 

cokDougl8sKalnett 

DIR. ‘ mR ~mmuws a’ 

COMYUNITYRELATKINS 

Ms. Lynn L Fkddy 

. 845DC-00000073 
3870 - 

OFFICE OF GENERAL COUNSEL 

WASHINGTON HEADQUARTERS SERVICES 

1166 DEFENSE PENTAGON 

ROOM ID197 

WASHINGTON, DC ~-1155 

FACSIMILE TRANSMISSION 

To: 

From: 

Anthony zacca&pilli 

Donald W. Perkal, 

Confiiation 

Fax Number: 

Subject: Linda Tripp 

Date: March 6,B98 

~FA~~W~S~~ - 

RECIPIJmT% CONFDRMA BONGED r”- 

TOTAL NUMBER OF PAGES, ~CLU~~~ THIS PAGE: 9 

4 two 

Linda Tnpp, F 

age ktter follows in which you are requested to inform your client, 

o a than e.in her duties. Accompanying the letter is a onepage 

statement of her new ci!a tm and refixtnce samples that will assist Ms. Tnpp in the 

pedomance of her new duties. 

awe 4 P 

Donald W. Perkai 

Deputy General Counsel 

845DC-OOOOOo74 

CONFIDENTIALIW NOTICE: This fauimlk conhlns confkkntbl, privikgcd in- ttpl lc Intended only for the use of the 

wwi%ee(S) narned above. n you am not the inkndcd recipknt* or !he employee of agent re8ponsibk for f5elifaing it to me WYKled 

rcdpient, you are hereby ndii that any - norcop~polWIhcsimik.or~b1610ofury~ninrefhnceontheantenUr 

ofthkfacsiie,iscbicXIyprohibbd. IIya,lPnRce~~~fscsimikinerror,psarcnotYyusimmcdiattlybytelephonr~rstumthe 

eMbe facslmik to us at the above address vt;l tha U.S. Postal Servke. Thank you. 
3871 

DEPARTMENT OF DEFENSE 

WASHINGTON HEADQUARTERS SERVICES 

11 M DEFENSE PEKTIGON 

WASHINGTDN, DC 20301-t ISB 

BY Facsimile Transmission MR 6 1998 

Mr. Anthony ZaccagnirJj 

Attorney at Law 

Semmes, Bowcn & Semmes 

250 west Pratt street 

Baltimore, MD 21201 

Re: LiridaTripp 

845-Dc-oooooO75 

In a letter of January 26,1998, to Ken Bacon, As&ant Secretary of Defuse ibr Public 

Affairs, Ms. Tripp’s attorney, James Moody, stated that “IEfxttaordinary press coverage of events 

surrounding [the Of&e of Independent Counsel] investigation has made it dif5cu.h for Ms. Tripp 

to leave home and has raised security concerns.” As a result, Ms. Tripp requested and was 

granted the opportunity to work at home pursuant to a J%xible Workplace Arrangement. As you 

are. of course, aware, the extraordinary press coverage alluded to by Mr. Moody has not abated 

since his letter of January 26,1998. Consequently, management of the Office of the Assistant 

Secretary of Defcase far Public A&irs has deter&& th+t Ms. Tripp’s continued performance 

of her current duties at this time relating to the Joint Civilian Orientation Conference (JCOC) 

would have a disruptive impact on the program’s success because of the likelihood of unwanted 

media focus on Ms. Tripp herselfboth during the preparations for the JCOC tour and on the tour 

itself. Moreover, the issue of Ms. Tripp’s security raised in Mr. Moody’s letter, as well as the . 

securhy of tour participants, are matters of concern to the Department. Also, I have been 

informed by the Office of the Independent Counsel that Ms. Tripp will be meeting with 

personnel of the O$lce some 12 hours per week for at least the next three weeks and that such 

meetings will occur during Ms. Tripp’s duty day. 

Trim, paid 

While the Department is prepared to mt Ms. 

admibtrative leave for the time she devotes to such meetings, management is 

concerned that this schedule is inconsistent with the requirements of her current duties relating to 

the JCOC pro8mm. 

Accordingly, ah carcM consideration of all of the circumstances, management has 

determined that it is impractical for Ms. Tripp to continue to perform her currently assigned 

duties and has therefore assigned her a new set of duties consistent with her position as a Public 

Affairs Specialist and also with her curmat work restrictions. Ms. Tripp’s new duties are 

described in the attached enclosure. Until further notice. Ms. Tripp’s first level supervisor and 

point of contact is Clifford H. Bemath, F?incipal Deputy Assistant Secretary of Defense (Public 

Affairs), whom Ms. Tripp may reach by telephone aq(oo 

ar, alternatively, by e-mail 
I would appreciate your transmitting the accompanying description of new duties and 

sample SOPS to h4s. Tripp as soon’as possible. If you have any questions, I may be reached at 

Donald W. Perkal 

\ 

JkputyGe3leralc0unse1 

EncIosure 

845-DC-OOOOOO76 
3873 

Duties : 

Deskside Standard Omratinq Procedures: (SOP) for JCOC: 

Currently, there is no single reference depicting in detail HOW 

the JCOC program is planned, coordinated and executed. The 

purpose of this SOP is to provide a comprehensive and detailed 

sour.ce for everyone (present and future staff members) involved 

in every aspect of JCOC planning and execution. This deskside 

SOP should breakdown the entire program by individual functions; 

and each function should be further detailed in terms of specific 

tasks involved. The following is a representative, but not 

inclusive, list of functions. 

l “_ 

0 

0 

History of the Program 

Purpose/Objectives 

Role/duties of Program Director (Separate Deskside SOP 

for function function performed by the Director, JCOC. 

Use attached format. 

0 

l 

l 

l 

l 

(Note1 

intent 

Detailed description of nomination/confirmation process 

Roles/duties of each member of the OSD JCOC Cadre 

(Budget, deputy director, others) 

Roles/duties of the Service Reps 

Roles/duties of the Service site reps 

Roles/duties of photographer/videographer 

Follow up aCtiOnS upon COn@etiOn of Conference 

This index is suggestive, 

. . 

rather than _ comprehensive. ._ The 

-1s tnat ror every runctlon associated with every aspect of 

conference planning, execution and follow-through, there is a 

desk SOP that fully describes that task and how it is 

accomplished. An example of the SOP format is attached.) 

This project is due to OASD(PA) 30 calendar days from date of 

receipt of these instructions. 

well as in printed format. 

Delivery should be on d$sk as 

From time to time, you may still be asked for information related 

to, and advice concerning, JCOC and may be asked to perform other 

related duties as determined by the DASD (Communications). 

845DC-oOOOOO77 
3874 

SOP# DM-14-1 DATE: 8/09/91 

DESCRIPTION Olp ACT-TX: 

Accountability of Metro Fare Cards for OASD(PA) users.. Pick up 

of new Metro Fare Cards to replenish stock, to include returning 

Metro Fare Cards when the amount remaining on the card is insufficient to pay for a trip on the Metrorail system during rush and 

non-rush hour periods. 

POINTS OF CONTACT: 

Admin NCO's 

Executive Motor Pool, Pm 3C345, S-1575 

STEPS INVOLVED IN ACCOMPLISRING ACTIVITY: 

1. Pick-up/Turn-in of Metro Fare Cards: 

a. Pick-up new cards at Pm 3C345 to replenish stock'. 

b. Turn-in cards that have less than $1, since they contain 

insufficient fare, to F&I 3C345. 

2. Issuing Metro Fare Cards: 

a. Cards will only be issued to OASD(PA1 personnel. Exceptions to this rule may only be authorized by the Director 

& Deputy Director, DM; DASD(PA), PDASD(PA), and the 

ASD(PA) . 

b. When a card is issued, Admin NCOs will complete the entry 

blocks of the Metro Card Ledger. (DATE, NAXE, DESTIHATION/PDRPOSE, TICX.ET#, and BAWINCE OUT.) 

C. Ensure that the recipient initials the INIT entry block. 

3. Return of Metro Fare Card: 

a. Without delay, Admin NCOs will complete the remaining 

portions of the Metro Card Ledger. 

USED UP, and INXT entry block.) 

(DATE IN, BALANCE IN, 

b. If the Metro Fare Card has been used up, the Admin NC0 

will enter "Yes" in the USED UP entry block. 

4.. Metro Fare Cards and control ledgers must be secured in DM's 

safe during non-duty hours. 

845-DC-o00078 
3875 

1. Memo, dtd 10 Feb 92, Subject: Authorization to Sign for 

Metro Fare Cards. 

2. Memo, dtd 21 Ott 87, Subject: Metro Fare Cards 

3. Memo, undated, Subject: Revised Instructions for the Distribution and Use of Metro Farecards 

APPLICABIZ REGVLATIONSAND DIRECTIVES: 

PREPABED BY: NCOIC DM 

845Dc-oooooO79 
3576 

n rc: Grand Jury Proceedings Mul 

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Q So if the information that we had -- 

A Good work. 

Q -- was that you catled Monica, apologized that your 

assistant wasn’t able to set up a meeting and explained that 

you bad been gone because of surgery, is that consistent with 

your memory? 

A It’s not consistent with my memory, I don’t have 

memory of that, but I hope I would have done that. But, no, 

I don’t have a memory of that. 

Q Then let me ask a related question there, which is 

do you remember whether on or about that date either 

President Clinton or Betty Currie might have contacted you 

and said “Could you give Monica a call, she’s been trying to 

set up this interview or chat”? 

A Well, I’m absolutely positive president Clinton did 

not call me. 

Q All right 

A Idon’tbaveamemoryofBettycallingme,but&e 

certainly could have. 

Q Is that xnnething that would have been memorable? 

A No. 

Q So it’s ‘a possible interpretation of the facts, but 

it’s not something that you recall. 

A I don’t. 

Q All right Then what we have is the WAVES mr 

A ~sisp~or~rny~~~~? 

Q No, no. I should make this clear. June 16th is 

when you actually had the meeting. 

A We’re talking about the meeting? 

Q Yes. The frrst meeting. And then a wuk iatcr, w 

have a document indicating that Monica thought that you bad 

told her in that first June meeting that you had told her 

that either tk President or possibly Betty Currie though 

that you’d gotten a burn deal. Did you say anything like &at 

Page 14 

on June 16th and that’s the time that Ms. Croft waved i 

MonicaanditsoMdsliketbatisthetimctbatyouthink:is 

probably the first meeting with Monica. 

A Yes. 

Q AIlright. Them’sthenaboutaweeklatera 

documentthat~havesuggestingtbattberearestiIIsotne 

questions in Monies’s mind about the job situation, but that 

you had told Monica during this June meeting that the 

President had told you that Monica had gotten a bum &al, 

basically had been dismissed from the White House unfairly. 

Did you say anything Iike that to Monica? 

A No. 

Q Is it possibfe that you said to Monica some&& 

Iike “I understand that you may have gotten a burn deal” and 

that you rnigbt have said that because that’s what Betty bad 

told you? 

Paf?CTM 3-26-B 

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Page 15 

to Monica, to the best of your recollection? 

A No. I’m definite about the President. That is 

absolutely a definite no. I don’t have a memory of Ek 

saying that. 

And, as I said before, I don’t have a distinction 

in my mind clearly of what we actually discussed on thy 

first meeting versus the second meeting. I have impressions 

of both those meetings, but at some point, with Monica, we 

did discuss her leaving the White House and we talked at 

length about the Deputy Chief of Staff and the role that she 

played. 

So I was very aware of that and I was very aware 

of how Monica felt about leaving, but I don’t - I don’t 

have any sense or recollection of sharing anybody else’s 

sense of that because I didn’t have any idea what the 

President thought about it and I don’t know that I actually 

knew what Ektty thought about it at that point_ 

Q Then let me suggest a way that you might have 

thought about it and a way that that cunversation might have 

occurred. And, again, I’m just trying to refresh your 

recollection and, if it fits, fine. If it doesn’t, just let 

me know. 

A Okay. 

Q But it seems to me that it’s possible that what 

happened was Betty, in talking to you about Monica 8~’ 

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letting you know that Monica would Iike to have a chat with 

you,shemighthavesaidsamethingIike,”Youknow,she 

doesn’tiikchcrjobwiththtDeparQlcntofI)efaLst,sbcwas 

dismissedfmmherWhiteHousejobunder~cesthat 

skthoughtwaaalittleuufair.” Andtheninyouraertof 

bmakingtbeiceandchaningwithMonica,youmightbave 

relayedtbatinf~enteher. IatIlataom&ingtbatyeu 

might have done? 

A I don’t have a memory of that, but I cert&Iy 

wouldhave-Imean,ImtsvcryinitiallyGmpatbeticwith 

Monica 

Q And that might have heen a basis for the empathy? 

A It was a basis for the empathy. I mean, I did 

not like the fact that she felt so wronged And I wasn’t 

sure what all the facts were, but I dont ’ have any clear 

memory at all of Betty telling me about any of that. She 

~~Y~l~~~ow~M~~~~d~~ 

teldmetbat~atsomepointIlarewthatandknowit 

today. 

Q So it sounds like what you’re saying is you do 

have a memory of having empathy during that June 16th 

meeting and that part of that - 

A No. I want to be really cl&r. I do not have 

tbesemeet&sf~edinmymindofwbathappenedonwbich I meeting, so I can’t say - I truly don’t. I just don’t know. J 

Page 13 - Pa@ 16 
3577 

n re: Grand Jury Proceedings Multi-Pagem 

Page 1’ 7 

1 These are impressions that I have now. These are feelings 

2 that I xmemkr having, but I cant ’ tie them specifically -- 

3 Imean,we’retallcingaboutnowaJune16thmeeting,soI 

4 can’t say what I felt back then or thought back then. 

5 Q Okay. Let me approach it more generally. 

6 A Okay. 

7 Q At some point, and Possibly in this first meeting, 

8 you bad empathy with what appeared at that time to be 

9 Monica’s situation and that you knew that Monica felt she ha 

0 left the White House under circumstances that she thought 

I wvre unfair, but you’re not sum whetha or not you got that 

2 information from Betty or even from Monica herself. 

3 A well, I kllOW 1 got it from h%XiitX. 

4 Q Alllight 

5 A I’m certain about that. 

6 Q Yes. 

7 A I don’t know -- 

8 Q Whether in addition - 

9 A Wlxther I got it from other places. I don’t know 

0 howmuchBettyt.oldmewhenshetalkedtomeaboutthat 

I situation. Because now what I know, I know it from so many 

2 0tlErsou.r~. 

3 Q Iunderstand. IsthattbekindoftbingtbatE&ty 

4 might have said to you in setting up something like this: 

5 A Yes. 

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I optimistic about a discussion, but had offered her a position 

2 as a detailee. 

3 A Incorrect. 

4 Q All right. You had at leas< though, discussed the 

5 detail position with her during that fust meeting. 

6 A Yes. 

7 Q All right. So there’s nothing about this 

8 particular document that I have in mind that’s in somewhat 

9 late July that refreshes your recollection about what might 

.O have happened on July 16th. 

,l A No, but it’s also not inconsistent with what we 

2 would have discussed 

3 Q InJune. 

4 AColTfXt. 

5 QlSee. 

6 A Correct. I mean, it could have been at either time 

7 because we did discuss that and we discussed the detailee 

8 Position at length and, as I indicated earlier, my first 

9 reaction or impression of Monica was she wasn’t interested il 

o that and then she called me back and said she was. 

.I I did look into that to find out if we could do it 

2 and we couldn’t do it. Her thinking that -- well, 1 don’t 

3 know that she actually thought that, but that’s not correct. 

4 I don’t know how she would have thought that she’d been 

5 offered the job. 

1 Q All right. Now, we also have information that 

2 Monica sent you some letter immediately after that first 

3 interview and I think we talked about it a little bit earlier 

4 andyoudesaibeditaskindofagushyletter,tbewaythat 

5 youdescribedit. Didthatletterhaveanyinformationiuit 

6 aboutwbatsbewantedbywayofajob? Orwasitsimplya 

7 thank you? 

8 A Mymemoryofitwasathaukyou,butshecouldhave 

9 reiteratedthetwo-actually,tbetbreethingswetalked 

D aheut,butIdon’tthinkitdid Mymemoryofitisjusta 

1 very short note. 

2 Q And what were the tluee things, if you can recall? 

3 A Prior to our meeting, she had met and interviewed 

4 in the National Security office. She was interested in 

5 anythingincommuuicatious. AndtimIhadbroacbcdtbcidca 

6 of detailing her to work on a women’s outreach project 

7 specifically with me. 

8 Q All right_ % next date, as we’re walking through 

9 this evolution of the job efforts, is the WAVES record on 

3 July 16th. And, again, with respect to thaG the question is 

I going to be whether or not you actually met with her or 

2 didnt, ’ and you indicated earlier that you’re not sure, bul 

3 we do have a document that’s &ted about a week later and 

1 that document suggests that Monica believed that you had 

5 offered her, and it’s possible that she was simply king 

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1 Q One of the things that this document suggests is 

2 thatherhopewastodothisdetailforawhileandthen 

3 possibly go from there into a communications related 

4 position Isthatsomethingthatyouhadspokenwithhe 

5 aboutduringeitherthatfirstmeefingoraleofthosefti 

6 telephone ds? 

7 A That’s vc@ mahstic and, yes, WC would have 

8 discusscdtha~ ‘AdetaiIistimxp&ic. Atmax,itcar 

9 be120&ys,dependingonberagwcyitcouldbelessand 

0 dependingonwhatwehavcIcftunadetailpa&ge. So1 

I know we would have discussed the fact that that’s a good wa! 

2 to get in the building, find out what other jobs am there 

3 and then it’s easier to get a job within the building once 

4 you’re in the building. 

5 Q I mentioned to you, I think that this document 

6 thatwehaveisdatedin-wlell,I’Ilbecvenrnorespecif~, 

7 July23rd AndthnifImcall,youmturnedfmmyourtrip 

8 abroad August 1st and since the July 23rd document talks 

? about this detail and she still hopes that the detail will 

3 eomcthrough,thatmakcsmethinkthatyouhadnot&tamiaai 

I yet whether or not the detail had been canceled. 

2 Does that square with yo_ur recollection of the 

3 timing of when you determined that the detail wasn’t 

I available? 

5 A No. 

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Q All right. Tell me why. 

A I think by the time I left, I knew that that wasn’t 

going to happen. I think I had already found out the 

information I needed. 

Q When did you leave? 

A What I’m less confident of is when I actually told 

her. 

Q Isee. 

A And that‘s where I’m confused. I want to help you 

on this, too, because I’m truly confused in my own rninl 

whether I saw her before or after. I think I saw her before 

I left the country, but I don’t close the door. 

Q When did you leave the country? 

A Well, that’s what I said. I’m not sure. I said 

5 earlier I think it was around 17.18, 19, some time in there. 

6 And that’s the piece, I apologize, I still don’t know, 1 

7 haven’t found out. 

B Q And you were gone for two weeks, getting back in 

9 August? 

D A IthinkIwasgone loor 12days. 

1 Q All right. And your belief is that before you left 

2 onthe17th, 18thor 19th,youhadalreadydetemCnedthat 

3 the detail wasn’t available, but you’re not sure whether or 

4 not you communicated that to Monica. 

5 A &Tect. 

Page 22 

I Q IfyouretumedfromyourtriponaboutAugustlsf 

2 aodwehavethisambiguousWAvEentryonthelsfitsbikes 

3 mc that you might have a specific rccollect+on of a meeting 

I ontheverysamedaythatyougotbackfromParis. Andso 

5 thefactthatyourreturnisontbesamedayasthis 

5 ambiguous WAVEentry makes me think that that may be 

7 som&ngthatwilljogyourmemofy. Anytbinglikethatin 

3 yolKmemoly? 

3 A Idon’tthinkIhadthatmeeting. IthinkIhada 

I nmting prior to my going. I don’t have a memory of her 

after I got back. I could have, but I don’t have that 

memory. And I would not have come in to work on the day I 

got back. I’m not a good traveler. And I know you need to 

know all this and I really will find out exactly when. 

Q But another way of interpreting that is if you did 

get back on August lst, it’s unlikely that that ambiguous 

WAVE entry relates to Monica coming in to see you. 

A No. 

Q It’s not unlikely? 

A No. As I said, she could have been waved in, 

possibly saying she wanted to see me. 

Q Isee. Isee. 

A And she could have - she knows a lot of people in 

the building. She could have gotten anyone to do that. She 

could have said, “She’s not here, but I’m going to hopefully 

Page 2: 

I see her this afternoon.” That’s not that hard to do. 

2 Q 1 See. 

3 A Or unusual. 

4 Q So it might relate to you, but it wouldn’t relate 

5 m something -- a meeting that actually occurred with you. 

6 A Correct. 

7 Q Good. We also have some information that some time 

8 in mid August Monica had told some pcoplc that she was having 

9 trouble with you and the job hunt situation. Let me give you 

0 afewmo~:detailsardthenwe’llrrytoagainplaoetbese 

1 details into the time line I’m trying to develop here. 

2 A Okay. 

3 Q Theres ’ a reference to Monica telling Ms. Bailey, 

4 who was the liaison for these kinds of jobs, that - thank 

5 you for your assistance and she is interested and umtinus 

6 to be interested in the detail that you had offered her. 

7 And, again, that’s August 25th. 

8 How does that square with the time line that we’re 

9 trying to develop? 

D A I don’t know what time line you’re trying to 

1 develop. You lost me for a second. 

2 Q Okay. We have what appears to be a meeting on 

3 June 16th. We have what may be a meeting on July 16th. 

P Wehaveyougoingtoparisandcomingbackandthen~havc 

5 in late Augusf August 25th, discussions between Monica a$ 

Page i-. 

Ms. Bailey where Monica appears to stiII be optimistic about 

working with you on this detail. 

Does that, that August 25th eommunieation, beMonica and Ms. Bailey, does that square with your 

lt%OlleCtiOn? 

A No, because - no. But it wouldu’t. Liz Bailey is 

tlx White House &&cm for the Depaxtment of Defense. 

AnythingMonicawantedtodo,regard&ofwbatitwas, 

would have to be approved by Liz 

SoIhadalreadyinstructedMonicaearlyonthat 

slxhacItoworkwithLizBaiIeyonanytbingskdid Shehad 

mworkwithKalBacon. soanyconvusatioasllcwouidlla~ 

heenhavingwithIizfitswithwhatsheshouldhaveb&n 

talking to Liz about. 

Now,herwantingadetailQ Butshesaidthatshewantedtotakethedetail 

that you had offered her. 

A Shecouldhavesaidthat. Imean,Idon’tknow 

tbatshesaid-tbatdoesn’tbaveameaningformeinany 

way. 

Q Well, it would be odd for someone to say “I’ll taJ-a 

the detail that was offered to me: if you had already 

withdrawn that offer. 

A Well, I hadn’t - you’re right. I don’t know that_ 

so that -- that doesn’t - it still doesn’t help me. I truly 

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do not know whether I saw her. 1 talked to her on the phone, 

I know, but I still don’t think that I saw her. 

Q I’mtryingtousethatasafulcrumaroundwhichwe 

can try to place in time the time when you told Monica this 

isn’t going to happen, the detail’s not going to happen. 

A My memory if it was I told her that in a phone 

call. 

Q Okay. 

A I thought I had wrapped all that up before I left 

exceptforIknowItalkedtoberoncewbenIgotback The 

when of that conversation, I don’t know when. 

Q ~lli&t. 

A If it was that late, it could have been that late. 

MysenseisLizBaileyknewthattbexewasnodetail. 

Q All right. Finally, to try to place one more fact 

into this potential time line, again, see if it squares with 

your recollection, we have reference to a discussion between 

Monica and Ms. Bailey some time in August and I’m not 

9 entirely sure when, where Ms. Bailey says to Monica, “Look, 

0 I’ve talked with Marsha and it looks like there may not be a 

I detail available. You Deed to talk with Marsha about that.” 

2 Did you talk with Liz Bailey about that? 

3 A Yt?S. 

4 Q All right. And doyou- ber whether Monica did 

5 have a conversation with you, possibly on the telephone, 

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A Well, yes. As I’ve said numerous times, I had a 

conversation with Monica and I told her that was not going to 

work. where I’m not clear is I thought all this was 

coadensedinamuch&ortertin&mmethanyou’rer;rPmillPtc 

allege that it could have occur14 in. 

I don’t dispute that it could have been drawn out 

overthattime. Tbat’snothowIrememberit,butpartof 

thatisbeeausethatwasalongerperiodoftimethan1 

thought I spent on this, though. 

Q LetmetrytoR-chamcterizewhatIthinkyou’ve 

just said, which is that it’s at least conceivable that what 

about the detail? 

Page 26 

happened in tinx is that you told Liz Bailey some time in 

August that the detail was not going to happen, that Liz 

BaileytoldthattoMonieasometimeafterwardsandthat 

h4oaicaalKlyoulUdtbStlzkp~convusatiooorpabapseval 

a meeting in person, but let’s suggest a telephone 

conversation, where you said the d&ail’s not going to 

happen. 

A That could have happened. That could have happened 

that way. 

Q All right. Okay. Fair enough. You had mexkmed 

earlier that you thought that Ken Bacon had not approved a 

detail for Monica. 

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Q What made you think that? 

A Well, now I don’t know, now that you’re asking me 

as if it didn’t happen. That’s just my recollection. I 

assume I would have gotten that from Liz Bailey. May& 

that’s what 1 wanted him to say. That’s just my memory of 

it. I don’t know. 

Q All right. 

A 1 still think that. 

Q Let me throw out another interpretation and tell me 

whether this makes sense or not. One interpretation might be 

that you had told Monica that there might be a detail, you 

were hopeful that Ken Bacon or Liz Bailey might say “It’s nc 

goingtohap~“andthentheywMlldinasensetakecareol 

her not getting the detail. 

Bailey calls you and says - or somehow 

communicates to you that Bacon has said it’s okay. which ttcn 

puts you in a position of having to do the dirty work, fc 

lack of a better word, and so you tell Liz, “Well, it turn 

out that I’ve spoken to people on this end and there isn’t a 

detail.” 

Liz then teIls Monica, Monica calls you and then 

you say to Monica, “Sorry, we just don’t have a &tail.” 

That’s another interpretation that throws in a 

couple more fact-s. How does that interpretation square with 

your xecollection of the facts? 

Page 21 

A The only piece of it that doesn’t square is the Ken 

Bacon piece. I found out, and here’s the only fact that I 

know, is that I technically could not have a detailee, so 

thatdriedup. IatthesametimehadcometodeeideI 

didn’t want Monica 

IamsurethatinmydiscussionswithLizIwould 

havetoldLizto~Monicatostayiaajobwhaeshe 

waswaatiaadnirM. Aadmyimpmssionwastkywankdto 

keep her, but I wuld be dreaming that up. But that’s m: 

impression. 

Q All right. Would it be consistent with your 

approach to handling people like Monica to try to see wberhez 

or not her interest would go away before you had to get in 

her face about it and say “It ain’t gonna happen”? 

A That’sfaireaoughtosay. IwantedMonicatocdme 

out of this feeling good about herself and feeling satisfied. 

Shewasayoungwoman,shehadaverygoodjobwhichfora 

lot of people that was a vay glamorous job. It had a lot of 

travel with it. 

The more-1 found out about the job and the 

interactiti I had with her, that was the appropriate place 

for her. And, yes, I really wanted her to stay there and I 

had hoped that she would stay there willingly and be happy 

andIwantedhertogetthekindofsupportonthatsideand 

I know I talked to Liz about that, of supporting her in 

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staying and make a career choice to stay there rather than 

try to move on. 

Q Did you have any further conversations with Liz 

Bailey about this at all? 

A I talk to Liz Bailey regularly, intermittently, 

because she’s our liaison. I am sure during the period where 

I was working on this amongst other things I would hav 

discussed it with her, but I haven’t discussed it, I don’t 

think, since that Period. 

Q And do you remember either specifically or 

generally any of these other discussions that you may have 

had with her? 

A No, but I don’t have specific memories of any 

conversations back around that period. I have snippets and 

impressions, but I - no, I don’t. 

Q All right. Do you have any snippets or impressions 

about discussions with Liz Bailey about this? 

A No, other than what I’ve said. 

Q All right. That’s what I meant to ask. 

A Yes. 

Q other than what you’ve aheady told us. 

A Monica in many ways is not unlike a number of 

people. The unique thing for me about Monica was her 

reference to being treated differently and treated badly. 

That’s not usual. I’m sure she’s not the only tits; but it’s 

Page 3C 

I not - it’s rare but that piece is different and in her 

2 refereneetotbeotberwomenandthatsbefeltlikesbewas 

1 singkdoutonsomebasii. ThoseweIethelwotbiD@&at 

4 were significant about Monica All the rest about her 

I disliking her job, liking her job, trying to fmd other jobs 

5 is very routine. 

? MREMMIfx Allright, Thatprettymuehdostsup 

3 thequestlonstbatIhadwithregardtowhatI’meallingtbe 

) timeline,forlaekofabetterword. WbatI’dhketodois 

1 now hum to another topic, if you’ll give me just w second 

(Pause.) 

MR. EIvth4ICK: Hem’s what I’d like to do. It’s a 

little early for a break’ so what I’ll do is get into a 

subject area., then we’ll break, but there may be some 

follow-up questions that we would like to ask based cm the 

timeLinebecause~‘1liaquirewitbtbegrandjurywhether 

they have any additional questions, so we may be circling 

back to that same topic. 

THE m=s: Fair enough. 

MR. EMMICK: Just so that you know. 

What I’d like to do is ask some questions about 

Webb Hubbell. 

THE =ESS: I’m so surprised. 

BY MR. Eh4hlICK: 

Q Let me first ask some background questions. How 

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long have you known Webb Hubbell? 

A Since we were in the tenth grade. 

Q Could you just give us a quick description of hc 

your friendship with him has evolved from that time until 

now? 

A For the most part_ except for probably a few years 

in there, we’ve stayed in touch. We’ve gotten in the las t 

probably -- probably 20 or 25 years, we’ve probably been 

closer. We knew each other well in high school, then w 

drifted apart. Probably in the early ‘7Os, we hooked up 

again and have stayed close ever since. 

Q Would you regard him now as one of your better 

fricllds? 

A He’s one of my best friends. 

Q E%?stfriends? 

A Mm-hmm. 

Q All right. What I’d like to do is focus a bit on 

the nature of your relationship as the two of you started 

working with the federal governmcn t them in ‘93. What 

,O position did he come to in 93? ‘

I A He was the Associate Attorney General. Initially, 

2 whenwefustcameuphere,hewastheonlypolitical 

3 appointee that we had in the Justice Department for some tinx 

4 period. He and Stuart Gerson, who was the acting Attorney 

5 General, I guess ran the Justice Department for us for - 

Page 2- 

I number of months early on and that was when I was the 

2 Director of -- 

3 Q Correspondence? 

4 A Yes, &respondence and Messages. Thank you. 

5 Q thuingthattimeperiod,ti’93,‘94timc~od, 

6 wereyouinfrquentcontactwithhim? 

7 A Yes. = 

6 Q Whatdoesfmquentcontactmeantoyou? 

9 A Every day. 

0 Q Good. Telephone eontact or lunches, breakfasts? 

I A u of the above. 

2 Q Wac you taking about business or just socialikq 

3 or both? 

4 A Never business, always socializing. 

5 Q He never talked about DOJ matters at alI? 

6 A No. Webb andVincewem--VinceFoster7 theywaewhatfthoughtwasthcqtitomofwftatagood 

K lawyer was in that they never discussed their business 

3 withanybody. 

3 Q At least not with you. 

I A At Icast not with me. 

2 Q Okay. There came a time when Mr. Hubbell ha 

1 ctmcems about the billings that he had with his law furn. 

t Do you recall that &? 

5 A No. I 

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In re: Grand Jury Proceedings 3-26-98 

I Q well, he -- 

2 A Maybe I don’t -- what are you asking? What’s Q After hc resigned, do you know what he djd 

3 the-areyouaskingmeforatimeoradate? 3 employment wise? 

4 Q I’ll jump f&ward and then I’ll come back. A I know that as long as he retained his law licze 

a A (%TeCt. 8 nothing wrong. And he had an office, I believe, u%? -- 

9 Q All right. Some time before that, did you have any 9 don’t know what the fm’s name is. 

o conversations with him about those billings? A friend of ours had given him space in his office 

i A Not speci&&ly about that. I’m not sure that 1 11 ~~~dI~~Webb~goi~to~~~te~~. 

2 everwas - until Webb pled guilty, I was not aware of 12 He was a lawyer. And that’s pretty much the extent of what 

4 than what others have told me. Q He stayed here in Washington. 

A Stayed in Washington. 

6 art&$ in the WWSpqNX. Q Were: you awaTe during 1994 of any efforts by people 

7 A correct. 7 in tbz White House to assist Webb Hubbell in fin&g 

0 articles? Q Any discussions of any efforts at all that yo-J’R 

1 A Idid. 

2 Q Did you ever ask him about them? A Webb was loved by tk people that knew him an? be 

3 A Yes. 3 haddotleanoutstan ob at the Justice 

4 tbcrcwmmanofus 

1 Q Can you place that in time a little bit? 1 innocence,soI~v~~of~y~fmdiaghimjobr,butI 

2 A We& I don’t know. 1 haven’t thought about it 2 knew of Webb txying to fmd employment, but I never kard 

3 that way. The very fucst article that I ever remember 3 anyoaeintheWhiteHousetallriogabouf”Oh,f’mgoingto 

4 aboutWebbwaswhen--IthinkthatIremember-was 4 try to get Webb a job,” but tkre were discussions abou: Tm 

5 The Wall Street Journal did a series of Webb Hubbell 1.2 5 sorry this is happening to Webb, I hope he’s okay.” It 

6 ~3or~~~d~t~~-~jo~~ut 6 ~‘t~~~~~p~wo~~ve~~~~ 

Q What people do you think would have helped him, 

B painful for Vince Foster as well, thslt type of article. 8 eithabeumsetheylikedhimalotorbecausetkywucina 

9 At some point, there were allegations that he bad 9 position to help him? 

2 inconceivable to me. I continued not to believe that until 12 wasinnocent. Idon’tthinktkrewasaperxmthatIkxw 

3 k pled guilty. And even when be pled guilty, I umtinued 13 ~~o~t~k~d~~~~~d~k~ 

4 not to fully believe them. 14 being politically persecuted. 

5 Q Before he pled guilty, he resigned from the Q When you had these discussions with Webb, son of 

5 bunt of Justice. 

7 A &nXt. 

? with him about the billing dispute? 19 A No. 

3 A No. Not - no. I didn’t have specific 20 Q Did he ever describe his clients at all? 

I conversations about the billing dispute, but I was very 21 A No. 

2 unhappy that he was resigning and didn’t think k should 22 Q Did he ever describe gettipg any work? 

3 resign. I was fumfy convinced of his innocence and felt 23 A No. 

3 Iike that he was being hounded and singled out unfairly. 24 Q Did he ever say that he had met people who had 

5 1 was probably one of the last of the true believers in his 25 connections to the White House at all? 

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A No, but he wouldn’t say that. He knew everybody in 

the White House. I mean, Webb was a well known figure and lx 

had captured the imagination of a lot of people, partly 

because he had become so popular at the Justice Department 

with the career people. They liked him a lot. He had opened 

up, I think, a lot of doors in the Justice Department for the 

career people. They felt more involved. 

We had also had a series of really high profile 

crises with Waco occurring during his tenure with Attorney 

General Reno. He’s a physically big man. He was a pro 

football player and his presence was eye-catching to people. 

He was well known, well liked. 

Q Just to summarize, it sounds to me like you’re 

saying you’re unaware of any efforts by any White House 

personnel to try to find him employment. 

A correct 

Q No referrals at all that you’re aware of? 

A What do you mean? 

Q From White House personnel referring business tc 

Webb Hubbell. 

A Absolutely not. 

Q You say “Absolutely not.” 

A We don’t do that_ White House Personnel, first 01 

all, I wasn’t working there -- 

Q I’m sorry. I meant the SXIId perSOnId. 

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Q People who work at the White House. 

A Oh, okay. Ask me again. I was going down a whole 

different road. 

Q Yes, I wasn’t sum, when you said “Absolutely not,” 

it sounded like you might have misinterpreted it. 

A Yes. Yes. 

Q Are you aware of any people at the White House 

making any referrals to Webb Hubbell? 

A I wasnt ’ then. Ive ’ heard now that there were. 

But, no, I never heard that from anybody. 

Q And when you say that you’ve heard now, am you 

referring to what you’ve read in the newspaper - 

ACOI-ICCL 

Q - or have you had any conversations with anybody 

on that subject? 

A No. No conversations. I’m referring to what I’ve 

heard in the media. 

Q Were you aware that Mack McLarty - well, you know 

who Mack McLatty is? 

A Yes, I do. 

Q What position did he have at the White House? 

A I believe at the time period that you’re referring 

to, he was the Chief of Staff. 

Q Have you ever heard of a person named Tnunan 

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Arnold? 

A Yes. 

Page 39 

Q How do you know who Truman Amold is and who is bc? 

A I know Truman -- well, that’s not fair. I have 

known who he was and I have met him through the years. He 

was a very prominent Arkansan, always referred to as the 

other one from Texarkana, ROSS Perot and Truman Arnold 

I knew him from back in the Fullbright days and 

then I got to know Truman and his wife Anita probably at the 

close of the ‘92 campaign. 

Q Were you aware that Mack M&arty called Truman 

Arnold about employment for Webb Hubbell? 

A I’m still not aware of that. 

Q Again, that sounds like a no. 

A Right I’m not aware of that. 

Q All right. Were you aware or do you know that 

Arnold eventually hired Hubbell? 

A I may know that. 

Q Okay. How did you come to know that? 

A I don’t know. I don’t know that for sure, but I 

think that - well, I don’t know that I know that, but I 

think that. It would not have surprised me, doesn’t surprise 

me. 

Q How might you have learned that, if you do know it? 

A I would have learned it from media. I mean, I 

Page 4! 

1 don’t believe that Mr. Arnold has ever told me that and 

2 know Webb has never told me that. 

3 Q Have you spoken with Mr. Arnold in person? 

4 A Numerous times. 

5 Q So just describe for us then, briefly, what the 

6 nature of your relationship is with Truman Arnold 

A FbeIy so&. He and his wife have become good 

friends. 

Q You have socialized on occasion with him and his 

wife? 

A Socializedwithhim. Whenevertbeywouldcnmeta 

townintbepast,Iwouldtrytoalwayshavedinnerwithtbtm 

and have lunch with his wife when she was here. PureI) 

social. 

Q Did he know that you were friends with Webb? 

A Yes. 

Q It strikes me that if ~OU’IC friendS with the 

Amolds and you’re iiiaids with Webb that when Amold = 

to hire Webb, that would be something that would come up in 

the course of a conversation. 

A lbe ’ m& that were ’ referring to, Truman and Webb, = 

don’t talk business in front of w-_ geXlauy. They%? 

pretty sexist that way. At least Truman is. I have never 

had a business discussion with Truman Arnold I don’t 

discuss what he does, who he hires. He’s never discussed it 

Page 37 - Page40 
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Page 4 

with me, I know him in a social context. And that 

particular group of men does not discuss tb5.r business 

socially with women present. 

Q Okay. So it sounds like you were awarc in some 

general sense that Amold may have hired Hubbeg, but you’n 

not entirely sure when you learned it or wi3etbe.r you learned 

it, simply from the media or possibly from some other 

discussions? 

A Webb was in business for himself when he left th 

Justice Department. He was soliciting clients. It woulc 

have been natural for him to solicit among the people that he 

knew. HckrrcwthcAmoids. ~t~~t~c~~~~~y~ 

another tither he was or wasn’t 

It does not surprise me that Mr. Arnold would have 

hired Webb. I’m delighted that be did. But it’s nothing 

that I would have inquired about. Or that they would have 

shared with me. 

Q If Webb and Mr. Arnold had a relationship of tha 

kind, can you think of my Reagan why Mack M&arty would make 

a call to Mr. Arnold to try to arrange for some sort of 

employment for Webb? _ 

A Well, Mack also is someone that had known Webb for 

a very long time.. We were all at the University of Arkansas 

together at the same time. We are a cIose-knit group of 

people. A friend of my friend is my friend. 

Page 42 

And I think Mack out of lcaowing Webb and knowing 

Tnrman,ifh:didthat,thatwouldhavebdenavaynatural 

thing for him to do, something be would have doot for anym 

thatwasaclosefriend. ~dI~~~d~b~~t 

that up immediately if he heard a friend was in need. 

Q Wae you aware or did you know that Mr. Arnold bad 

helpedtoarrangeforsevcralofhisfriendstohireWebb 

Hubbell? I’ll give you a list of nm. A fellow by the 

name of Beznard Rappapoti A fellow by the name of Wayne 

Rcaud. A fellow by tbc name of John I&ores. A fdbw by the 

nameof- in fact, I don’t know if it’s a fellow or not, 

maybe I’m being sexist - C.W. Corm. 

A It’s a man. 

Q A man? Au right. ~dyou~owor~youa~ 

that Mr. Amold made arrangements for those people to hine 

Webb? 

A At the time, I didn’t, but it doesn’t surprise me. 

Q But you do know it now? 

A I~ow~tI~v~~d~dX’~~~~ 

) onallthosemenandallthoserecords,soI’msrceptingthat 

I that’s the case. 

1 . Q Did you have any discussions with Webb about that? 

I A No. 

I Q Did you have any discussions with Mr. Arnold about 

i that? 

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A No. 

Page 4: 

Q Do you know Mr. Rappaport, Reaud, Moores, or Conn 

A I know all but Mr. Moores. I only know him -- I’ve 

been introduced to him And when I say know, I have met al 

those people socially. I don‘t know them. 

Q I asked the question earlier, are they the people 

whose names would be in your Rolodex? 

A Mr. Moores isn’t. Mr. Conn and -- I know 

Mr. Rappaport the best, but, yes. Except for Mr. Moores. 

Q Are they among the very close-knit group that yoc 

were referring to earlier? 

A No. 

Q The Arkansans? 

A No. Theyre ’ Texans. 

Q -. Texans? Well, there you go. 

A We make a distinction. They are close friends of 

Mr. Arnold, 

MR. EMMICK: All right 

THE FOREPERSON: Mr. Emmick? 

MR EMMICK: Yes? Is this a good time for a break? 

THE FOREPERSON: Yes. 

MR. EMMICK: Having mentioned the great state ol 

Texas, that’s an appropriate time for a break. 

THE Wri’NE?Ss: Who’s the Texan here? 

MR. EMMICK: Sol. 

Page 4 

1 THE WITNESS: ti right 

2 h4R. EMMICK: Let’s take a break. Thank you. 

3 (Witness excused Witness recalled.) 

9 ~ffl~~~~~x~~~you 

5 thatyouarestiuunderoath. 

6 THE wmG%s: Thank you. 

7 hDLEMhfRX Dowthaveaquorumpnzsent? 

8 THE FOREPERSON: Yes, we do. 

9 MR.EMMIC& ~~~y~~o~~~ 

o thegrandjwyroom? 

1 THE FOREPERSON: No, there are not. 

2 h4.R EMMICK: Why dont ’ we continue? We were askin 

3 questions about Mr. Webb Hubbell. 

4 BY MR. EMMICKz 

5 Q One of my follow-up questions relates to a comment 

6 t&it you bad made. sugssting that W&b and Txuman Arnold.did 

7 not - were somewhat sexist and did not talk about - 

8 A I said Truman was. 

9 Q Oh,I’msorry. Mymist&e. Trumanwas. Andthat 

!O he didn’t d.iscu& business-related matters with women. 

:1 A Thats ’ my impression. 

2 Q And you also indicated that Mr. Hubbell didn’t 

3 discuss business matters at ie&t with you. 

4 A yes. 

5 Q The follow-up question that I had is when YOU mei 

Page 41 - Page 44 
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Page 4 

socially with either Mr. Arnold and Mr. Hubbell ar.d their 

wives, did you have any conversations with the wives about 

any of these employment opportunities, let’s call them_ 

A No. 

Q None at all. 

A None. 

Q All tight. They didn’t raise the subject, you 

didn’t raise the subject? 

A Only in generics. And let me separate “the wives.” 

None with Anita Arnold, Truman Amolds ’ wife. Susie Hubbell 

is aLso a close friend of mine. We have agonized over their 

family situation. They have four children. At the time, all 

four were still in various stages of being at home. ‘Ihey had 

son that was fmishing up college, but all the other children 

were in college or actually were in grade s&001, high 

school, and colkgc. Sbc was always con& about what was 

going to happen with the family. 

So in that context, we agonized constantly over how 

the-y would get by. But we did not ever discuss specifics of 

how they would get by, other than in the context of what I 

could do to help them. 

Q Did she ever say anything like “Thank goodness the 

White House is helping us auf”? Anything like that? 

A Ihe White House wasn’t helping them out and she ma) 

have said that. 

Page 4C 

Q ~d~~~~y~~~~~g~w~b 

has been able to pull in a lot of business”? 

A No. I don’t think Susie felt that. I think her 

fear-heranxietylevelhashardIyeverdiminishe& I 

tbinkshetothis&yba.sgreatanddeepconcernsabouthow 

they’re going to get by and I don’t think that was ever 

alleviated because once he pled guilty, Webb had tnzmendous 

fiaes and back taxes that are owed. 

MR. EMMICKZ The record should reflect that 

Mr. Wisenberg has entered the grand jury r00m. 

BY MR. EMMICK: 

Q She bad those conc.ems - let me just follow up On 

titatabit. DoyoulmowabouthowmuchmonqWcbbwasmaking 

during this time period? 

A I do not. 

Q Do you have the impression that he was not making 

much money and that’s why their financial circumstances 

seemed dire to Anita HubbeIl? 

A No. Susie Hubbell. 

Q Susie Hubbell. 

A Anita Arnold, Susie Hubbell. 

Q My mistake. So did you have the impression that be 

was not making much money? 

A It was my impression. But that’s relative. That 

i mayhelittletome+ifIhadafamiiyoffourkidsandthey 

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Pagt: 17 

were all in school, it might bc a different -- but my 

perception was that they were not bringing in an inccze 

sufficient to support a family of six. 

Q All right. Let’s talk a little bit about Erskine 

Bowles. 

A I met him in ‘92 when we worked on the economic 

conference together that I talked about earlier. And he ws 

the Deputy -- his first job in the administration was he KX 

the administrator of FDA, then he became a Deputy Chief c5 

Staff and is now thz Chief of Staff at the White House. 

Q Do you know him socially? 

A yes. 

Q Do you know his wife socially? 

A bSs so. shes ’ not here aS Often, So I know 

Mr. Bowles better. 

Q I’m going to ask you a question that’s somewl~~ 

similar to ones that we’ve asked earlier, that is, were 

youawarca&youkmwthatMr.Bow~shadmadcsanc~ 

to friends of his in an effort to try to fmd Webb 

employment? 

A I’m only aware of that from the media_ 

Q No discussions with Mr. Bow& ahout that directly? 

A No. 

Q No discussions with Webb about that directly? 

A No. 

Page 9, 

Q Any discussions with anya associated with tbe 

White House on that subject? 

A No. 

Q Allright. WhataboutVemonJordaa? Howdoyou 

know Vernon Jordan? 

A Id~‘t~ow~~~~. X’vemethim. I 

know of him. He% a historical figure. Very prominent 

ileaeinwasi@ton. Ilmewthasbcwasalong-timcfrimd 

ofMrs.Clintonandth:Pre&dent,datirqmanyyearsbadr 

I think it’s a 2O-som&@ year f&.&hip. And I’ve gotten 

to know Mr. Jordan through social contacts since I’ve ban in 

WaShington. 

Q Do you regard him as a friend? 

A He’s an acquaintance. I don’t know him because 

justdon’tinteractwithhimtbatmuch. Ilikehimverym~ 

and I think he would say the same about me_ 

Q Were you aware that he helped Webb in finding jobs 

at all? 

A No. Only what I’ve read. 

Q Is one of the things that you have come to learn 

the fact &hat Vernon Jordan helped Webb by putting him tour’ 

with Revlon? 

A 1 don’t know that that’s a fit, but I’ve read 

that. 

Q Do you know that from any other sources at all? 

Page 45 - Pa_gt- 18 
3585 

nre: Grand JuryProceediogs MUlti-Pag? 3-26-98 

I 

Page 49 

I A No. 

2 Q Either from talking to Webb or from talking to 

3 others or talking to Vernon Jordan himself! 

4 A I’ve never heard anyone discussing Webb’s clienti 

s at the time when Webb had clients. 

6 Q He didnt ’ discuss his clients at all? Did he ever 

7 mention the fact that Revlon was a client? 

8 A Webb? 

9 Q Yes. 

LO A No. 

,I Q Did he ever dkxss - 

:2 A I wish I had known. I use that makeup. 

13 Q Togetadiscount? Didheev~discussMcAndrcws& 

;4 Forbes? Does that name ring a bell? 

.S A I’ve never heard that before. I don’t think. 

.6 Q Okay. McAndrews&Forbesisth: holdingcompany 

7 that owns Revlon, if that helps with any recollections. 

8 No? All right. 

9 Did you ever have any discussions with President 

LO Clinton about any efforts to try to get jobs sent in the 

!i direction of Webb Hubbell? 

!2 A No. 

!3 Q Any discussions about Webb Hubbell’s fmanciai 

!4 situation? 

!S A Ineedtotalktomylawyer. 

1 

2 

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4 oath. 

5 

6 

7 Q 

MR. EMMICK: %re. 

Page 50 

(The witness was excd to confer with counsel.) 

THE FOREPERSON: &fs. Scott, you’re StiIl under 

MR. EMMICK: We’re back on the record. 

BYMR_EMMXCR 

The question was have you ever discussed Webb‘s 

8 fmanci& situation with President Clinton? 

9 A Eve?! Yes. I have. But in the context that I 

o discussed it with anybody and everybody. 

1 Q Meaning what? 

2 A Meaning that I was concerned about him and his 

3 family of six and particularly as to - I think I would have 

4 talked about it more after Webb was in prison. 

5 Q What did the President say? 

6 A I don’t remember what he said. He’s always been 

7 concamal about W&b. Hc cars about Webb. But I don’t have 

8 a memory of a specific conversation. 

9 Q Do you have a general impression of things that he 

0 might have said or attihldes that he might have had, similar 

1 to the lines that you’ve suggested? 

2 A Only that he was a long-time friend, he cares 

3 very much for him. l%ey were very close friends and he 

4 wants -- I think he’s always wanted to make sure the family 

s is okay. 

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Q Did the subject of Webb’s financial situation come 

up a number of times in conversations between you and the 

President? 

A No. 

Q A few times? 

A I think it would have been more of me bringing it 

up. Evay now and then the Prcsidcnt would say “Hows ’ Webb 

doing?” And I would probably say, “Okay. Hanging in there 

Its ’ tough.” 

Q Is it your impression that he would ask you that 

because be knew you were friends with Webb and in fquen 

contact with Webb? 

A He knows Webb and 1 are close friends. 

BY MR. WISENBERG: 

Q-- Well, tell us everything YOU nzmember - because 

Ithink,ifI remeInber co-iy, you xemembez a discussig 

you remember discussions with the President or at least a 

discussion with the President about Webb’s financial 

condition, so tell us everything you renrzrnber about that. 

A No. I don’t remember a discussion with ti 

President about his financial condition. I remember the 

Prcsidmt caring about Webb and being cotuxr~& about Webb's 

financial condition for his family. I don’t have a memory of 

the President actually saying “What is Webb’s financial 

condition?” 

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Page 51 

Any of the questions you’ve asked about other 

people, I’ve not had that kind of conversation with the 

Pi&dent. l%e Pmsideat cared about Webb, they m cfose 

fria&,andkwasconccmcdaboutwhatwasbapp;ningtothe 

kids in pa&ular. 

Q Allright. Telluscverythiagyoueanremembera: 

bestasyou can%member about this eonwcTs8tioI1 or 

conversations. 

A IjUthaVe. 

Q That’s all you remember? 

A I mean, it’s just a generic impression. I don’t 

;! remember his exact words. That’s my impression of it. 

f BY MR. EMMICKz 

+ Q Do you have a reco&etion that it’s one 

j umversation or a couple of amvetsahns on that subject? 

5 A As I said before, it would be something that I 

1 mightbringupevcrynowandtbap. Youwanttoknowhowmany 

3 is every now and then? 

> Q Or just a ballpark. It’s one thing to have 25 

) conversations, ii’s another to have three, it’s another to 

I have only one. 

E A How many years has this &en going on? Liie four 

i years? 

I Q Which is the “this”? 

j A You’re talking about Webb Hubbell? 

- 

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Page 52 

Q Yes. It would have been since about 1994, so -- 

A FZight_ So were ’ talking four years. 

hfR. WISENB~RG: He resigned in Spring of ‘94 am 

pled guilty in very late ‘94. 

TTE wrr~~ss: Okay. Four years. Three and a half. 

Once every three or four months, six months. Lie I say, it 

was not conversations about Webb’s financial condition. It 

would be in the context of “How’s Webb doing?” “Tough.” 

That kind of thing. Nothing the President could do, he was 

just concerned, I think, about his friend and particuhuly 

about the kids. 

BY MR. Eh4MICK: 

Q And how specific were you in a position to be in 

reporting on bow Webb was doing financially? 

A I didnt ‘ know. I assumed it was tough. I thought 

they were having a very difficult time. That’s stiII my 

impression, but I’ve since come to learn that’s relative, 

what is considered tough. 

I think given the context of ail that Webb owed and 

aI the different entities, that loomed large, so I think 

that weight neyer leavea Webb or his wife Susie and I think 

then: is -- they have extreme difficuIty but there again, 

that’s relative. 

Q So you were reporting to the President, and not 

ascribing any particular meaning to reporting, but you were 

Page 54 

letting the President know that Webb was having some 

financial difficulties. 

A No. In the amtext of fiiendship and talking 

to my friend, Bill Clinton, when he would ask about his 

friend., Webb HubheIl, “How is Webb doi@ I would say, 

“It’s tough.” And that - if that is interpreted as a 

financial inquiry, then that’s a financial inquiry. 

Q Isthatwhatyou’meantbyA ThatiswhatImeant Yes. rIIX%IIltitiIlthe 

whole sense, Webb has an extmmely tough Iife now. 

Financially, he’s ruined. Professionally, he’s ruined. 

Psychologically, it has been very difficuh. It has taken E 

tremendous toII on the famiIy. 

Q Did he ever ask anything Iike “Is he getting enough 

work?” 

A I don’t remember that 

BY MR. WISENEERG: 

Q How often did you talk to Webb? How often did you 

~toW~b,~you~ed~~at~l,w~~~~ 

prison? 

A At least once a week, I believe. 

Q And about how often did you talk to his wife when 

he was in prison? 

A I tried to every day. I didn’t always do it every 

day. 

Page 55 

I Q Did you ever convey to either Webb or his wife, 

2 Webb Hubbell or his wife, that people in tbe Whh House wxc 

3 concQned about him counta suing The Rose Law Fii? If tbpy 

4 sued him for tbc money tbzy claimed k owed tixq that people 

5 in the White House were concerned about him counter suing? 

6 A I don’t remember that. 

7 BY hfR. EMMICK: 

8 Q You don’t remember that thete was discussion -- 

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A I don’t remember either of those, the suit, counter 

suit and I don’t remember a discussion. 

BY MR. WISENBERG: 

Q I’m not saying that there necessarily was a countel 

suit, but the question would be based on a fear or a 

possibility that Mr. Hubbell might counter sue The Rose taw 

F~~~~~~. Youdon’tnxnemtxxsayingtohim 

OrtohiswifethatpeopleintheWhiteHouscwereconcPmsd 

about him counter suing becau~ it might somehow implicate 

the First Lady? 

A I don’t know that they were concerned. You’re 

taIking about something I don’t know. 

Q Okay. But you don’t - whether or not you knew 

that they were concerned is a sIightIy different question. 

Did you convey that to Webb Hubbell or his wife, that people 

in the White House circle were concerned about him counter 

suingTh@RoscLawFiibcCauscitmightdragin-somehow 

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Page j. 

implicate the First Lady? 

A I don’t know that people in the White House were 

concern& as I said, so since I didnt ’ know whet&r thq 

wexe concerned, I don’t think I could have had that 

conversation with Webb. 

Q So you didn’t have that conversation with Webb 

Hubbell or with hi% wife, a conversation to that effect? 

A About peopfe in the White House being concerned 

~a~b~e~tw~b~go~~~~~~ 

fum? 

QI@@. 

A No. I don’t know that anyone in the White House 

was ever taIking about that or conceined about that. 

Q Right_ But that’s a separate - I understand 

you’= making a logical infefmce, that you don’t even know 

thattheywereumcemed,butmyqueationismorespecific.. 

Irrespeaive of what you knew or not, my question is did you 

collvey to either Webb Hubbell or to his wife that people in 

~~~Ho~~le~~~~t~f~a 

counter suit to the Rose Law Firm’s civil suit? 

A So in other words, would I Iie to Webb? Make up 

something,makeupthistalethatpeopleinthewhittHoua 

were concerned about this? - 

Q The question just is -- 

A I thought I just answered it. 

Page 53 - Page-56 
n re: Grand Jurv Proccedinrrs 

- 3587 

Multi-Page” 

Page 57 Pa,3c 59 

1 Q Well, I’ll ask you to answer it again. The 1 things Ive ’ ever heard said or alleged to have been said or 

2 question is did you convey -- whether or not you knew people 2 rumored to have been said. 

3 were concerned 0; not, did you convey that information to 3 Q So you don’t think you would particularly remember 

4 Webb Hubbell or to his wife? 4 it? 

5 A I don’t think so. No. 5 A 1 would not particularly remember it. 

6 Q Okay. Is that something you think you would 6 Q 1 take it the President is a person of some 

7 remember, if you conveyed that information? 7 importance in your life, because of who he is and becauz of 

8 A No. 8 your long-time friendship with him. 

9 Q &cause? 9 A Absolutely. 

0 A I don’t have any reason to remember it. 10 Q The First Lady is an important person in your lift 

1 Q Okay. 11 A Absolutely. 

2 A I don’t even think I know it. 12 Q Andifyouconveyedtosomebodythattheywere3 Q aright. 13 that people in the White House were umcemcd about him 

4 A I mean, we’re taking about something that I think 14 taking an action that might implicate the First I.&y in some 

s is whole cloth here. 15 way or harm her in a public relations sense, you don’t think 

6 Q Okay. 16 you would remember that? 

7 A But--so - no. Thzrc’s nothing unusual about 17 A We’re talking a theoretical about a theoretical. 

8that,to remember if I didn’t - it’s kind of a funny line of 18 ‘Ilxmetically, would I remember Somlhing that theoretically 

9 questioning because it’s all +emeral. Where does it come 19 happened that might theoretically harm the First Lady. 

0 from? 20 That’s what we’re talking about because I have said I don’t 

1 Q Okay. And, again’ the question as I just asked 21 know what you’re talking about and I don’t think it eve 

2 it was -- as I just asked it was strictly - it strictly 22 occurred and I don’t know what you’re talking about. 

3 hadtodowithcollvcyingtlcoLMxm by the White House’ pcopk: 23 So would I be concerned about things affecting th 

4 in the White House circle, about the filing of a counter 24 First Lady? Absolutely. 

5 suit. 25 Would this stand out in my mind as being something 

Page 58 Page 61 

1 Now Iet me add this other element onto it, that 1 bigger or big enough so I would rememh it? Not 

2 therewas- did you convey to Mr. Hubbell or his wife 2 necessarily, because I’m not a lawyer. I don’t know what 

3 thatpeopleintbeWhiteHousecirclewereconcemedabout 3 that would have - what kind of meaning that has in the 

4 him ftig that suit, counter suit, because it might 4 context of things. 

s implicate the First L&y? Is your answer thesame,that 5 ~my~~Id~‘t~~-itd~‘t~d 

6 you don’t - 6 verybig,Idon’tseethestretchtotheFirstLadyother 

7 A I have no memory or knowledge of a suit/counter 7 thanshewasaf8wpartnerinthatfirm. Idon’tseeho~ 

8 suit. I have no knowledge of anyone in the White House 8 Mr. HubbeIl’s dispute with his partners in that fum has any 

P talking about this alleged suit/counter suit. I have no 9 bearingontbeF~Ladyinasvaytbat’snegative. Ithink 

o knowledge of anyone in the White House talking about an 10 those ax unrelated facts and I don’t see the connection, so 

1 alleged suit/countex suit and its implications with the Fti I 1 in my mind, it wouldn’t stick out. 

2 Lady. And I have no knowledge of talking about any of those 12 Q Well, what if Mr. Hubbell was counter suing - was 

3 ti permutations of that question with Mr. Hubbell. Does 13 possibly going to counter sue and as part of his counter suit 

4 that answer the question? 14 say “I’m not tbc only ooe, I’m not the only one who engaged 

5 Q That amwers that question. But you don’t think IS ~f~b~~~~o~p~~~f~ 

6 that it would be something you would necessarily nznemk 16 billing”? Could that caaceivably implicate some of those 

7 that people in the white House would be concerned about this 17 partners who engaged in false biIIing’ if he was alleging 

8 rather major figure. who’s in prison who might be filing a 18 that? 

9 counter suit’ you don’t think that would be something that 19 A Your question -- whats ’ your question? 

0 you would rmxmbm if you bad conveyed that to Mr. Hubbell? 20 Q Well, you had just explained to me why you don’1 

1 A There have been hundreds of allegations about 21 s& any cooktion or wby you would be con& or anyme in 

2 almost everyone I work with in the White House and hundreds 22 the White House would be conT_ed about some counter suit 

3 of allegations made against Mr. Hubbell. his ‘ one does not 23 Webb Hubbell would file against The Rose Law Fii. 

4 have any legitimacy in my memory and it doesn’t stand out as 24 A Webb Hubbell’s transgression was a private one that 

5 having any legitimacy compared to all the other hundreds of 25 he took against his law fum. It had nothing to do with 

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President Clinton and it had nothing to do with Mrs. Clinton 

except that she was also a partner. So in that sense, 

Mr. Hubbell took money from her as well. 

I do not see bow this mythical thing that I’m 

supposed to know is anything that could comment on. I don’ 

know what you‘re asking me to say to you other than I’m 

saying I don’t know the conversation, I don‘t have a memory 

of it. So you’ve got me totally confused about what you’re 

wanting me to do for you right now. 

Q All I want is truthful answers. 

A Well, maybe I’m not coming Up with the right Words 

because you and I arc talking at each other, not with each 

other, on this. 

Q My question was simply -- let me try to rephrase 

it. 

A Okay. 

Q And it Was prompted by your statement a muple of 

answers ago that you wouldn’t see how anybody - to the 

effect that you wouldn’t see bow what happened with n*: Roaz 

Law Firm would be of concern in the White House. 

Do you think it would be of potential concern if 

people in the White House thought Mr. Hubbell whs ftl& a 

counter suit against the people who had been his partner: 

when he stole mcncy from the firm saying “You guys stole 

money, too,” do you see how that could bc a potential concern 

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A Y0u’l-e asking me t0 C-Q-t OII SOWthhg that 

wasnt ’ a fact for me, so we’re just pretending here+ we’re 

playing pretend, let’s pretend - 

Q It’s a hypothetical question. 

A I&‘spretendtbatIhavehadknowIedgeofthis 

conversation and what I have said is that I don’t see the 

conn&ion barnat Webb Hubbells ’ a&as uo a pczwd kvd 

and Mrs. Clinton. 

Do I care about bow things might affect 

Mrs. Clinton? Absolutely I do. 

If I thought in any way something would affect her 

adversely, would I pay attention? Yes. 

I didn’t see the connection in this mythical thing 

that you’re talking about. Since I didn’t have the 

conversation that I know, didn’t think of the amversatioq 

now sitting here today, if I bad a lawyer guiding me 

through it, I might arrive at a conclusion that this might 

be something that might in some perverse way affect 

h&s. Clinton, but Mrs. Clinton didn’t overbill partners; 

Mrs. Clinton was not involved in what Webb Hubbell did or 

does, so I do not see why that would stick in my mind or 

raise red flags for me. 

Q When you would talk to Susie Hubbell during the 

time that her husband was in prison, would you tell her the 

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truth? Would you tell her the truth? 

A About what? 

Q Anything. Do you recall lying to her about 

anything? 

A What do you mean? D&me it Give me some terms 

here. 

Q Lie, tell a falsehood. Do you recall -- 

A Yes. I told Susie she looks good wkn she doesn’t, 

I told her that she’s been losing weight when she hasn’t. 

I’ve told her that life will get better when it doesn’t. 

So, yes, I lie in that way alI the time to her when she’s 

feeling down. Absolutely. 

Q Other than those kind of Iies, do you remember 

telling her any lies? 

A I don’t have a context for that. 

Q If you had told her that people in the White House 

were concernezI about Webb Ming a countez suit or that his 

friends were concerned about bim f&g a counter suit 

against The Rose Law Firm, if you had said something l&c 

that, I take it that you woubin’t have made that up. You 

wouldn’t have lied, that wouldn’t be a lie? 

A If I had said that, since I don’t remember anyone 

intheWhiteHouseeversayinganythingaboutthat,ifIhad 

said that to Susie, I would have been lying to her. I would 

have been making up something to her, since I have absolut@ 

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no xusnory of anyone in tbc White House mr wntioning to M 

anything about this counter suit notion. 

Q Okay. So you don’t remember ever teIIing it to 

her, ever telling it to her? 

ACOrEZt. 

Q And since nobody in the White House ever said 

anythiagtoyouabozrti5ifrouhdtoldtra.youw~dhavt 

been lying? 

A &-nXt. 

Q And the same for Webb? 

A correct 

MR WISENBERG: Okay. That’s all I have on that 

line. 

BYMR. EMMICK: 

Q I’m going ask, I guess, a related question. You 

kncwthat-ordidyouknowtbatTbcRosctawFirmwassuing 

Webb? 

A I don’t know. I’m sure I know that, There’s beeq 

way too much said and written about Webb for me to know 

specifically what I know any more. 

Q I guess that would have been of some concern to 

Webb, to have Iris own law firm suing bim? 

A I’herewcremany,manystageswithThcRoseLaw 

Firm. I think that was possibly one of them. I 

Q My question is just going to be what do you recall ] 

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I about discussions with Webb about the fact that his fhn was 1 Ix - usually it was “Is Susie okay?” “How’s Webb doing? 

2 suing him? 2 That kind of -- very generic. She’s a very private person, 

3 A There again, I didn’t taI.k -* I am not a lawyer. 3 very sparse in her words. 

4 A lot of what you all do -- I used to say it dozsn’t interest 4 Q Did she ever say anything to you indicating that 

5 me, now it annoys me greatly. That is not how I have a 5 any of her friends or the President’s friends or persons 

6 friendship with Webb. I have a friendship as -- this is 6 associated with the white House were helping Webb out by 

7 a childhood friendship. This is based on - he’s like 7 making referrals of business to him? 

8 a brother to me, hz’s part of my family, I knew his 8 A She didnot. 

9 family. I’m not his legal advisor, I’m not his financial 9 Q Was she ever more specific about ways that she was 

o adviser. 10 considering helping Webb? 

1 We didnt ’ talk about those things. I talked 11 A She was not, I don’t know that she ever helped him 

2 about bk psychological state of being. I talked about how 12 at ail, other than to pray for him. 

3 tk kids were doing. I taIked about how Susie was doing. 13 Q All right. Do you know whether she was aware o: 

4 I talked about, you know, whether he had any vision of a 14 ofher people helping him at all? 

s futureorwhatwasbispresentgoingtobe. Ididoottalk 15 A I’m not aware that She was aware of anything. 

6 about his legal stuff. 16 Q AlI righrt It sounds to me like you were a fairly 

7 Q Right. Except insofar as they may have been of 17 chief source of information about Webb to both tbe President 

8 conm to him bemuse you wanted to be supportive and you 113 and Mrs. Clinton. Do you think that’s fair to say? 

g wanted to be empathetic and you wanted to be a friend. 19 A If what I was about was information, there was - 

0 A Webb talked to his lawyers about that. He had 20 because there was scant little conversation about Webb. 

1 plenty of people that he discussed that with The last thing 21 Q 1 guess what I’m asking is do you know whether 

2 bcwantcdtodowhenhewasawayFromthatwastotalltabout 22 there were any other sourazs of inFormatioo about Webb goiq 

3 those things. 23 to the President and going to Mrs. Clinton? 

4 Q Soareyoutellingusthattheanswertothe 24 A I have no i&a. 

5 question, did you ever talk with Webb about a lawsuit filed 25 Q But at least they were aware that you were in 

Page 66 Page 68 

1 againsthimbyl-heRoseLawFium,tbeanswler is no? Is that 1 something like weekly contact with Webb? 

2 what you’re saying? 2 A Idon’tthinkthzyknewhowoften. Wenever 

3 A I don’t know because if he had said - 3 c?iscusscdhowoften,wbenandbow. Mysmseistbatituas 

4 hypothetically, theoretically, he could have said “I don‘t 4 probabIycomforfingtobdhoftfremthatIsawW~bandtfrar 

5 know what’s going to happen, there’s a lawsuit going on.” 5 wassuflicientandIthinktbeybothprobablyassumedthatif 

6 I would say, “How are you feeling about it?” That h how 6 thcrcwasanytbingthatwasbappeningtohimortbefamily 

7 Iwouldhavetalkedtohimaboutit. 7 that I would let%zm know. 

8 Q Right. And what would you have said? 8 Q Asyou’re@eakingwiththemaboutWebb,doesW&b 

9 A If he would have said it I don’t - 9 ever ask you to let them know anything? 

0 Q Did he say it? 10 A LetrnecIar%ythe”tfiem”part 

1 A I don’t have a memov of this lawsuit. f don’t 11 Q Okay. 

2 lcnow about it. 12 A 1 had very, very few occasions at which I ever 

3 Q Okay. You mentioned that you bad discussed Webb’s 13 ta.Iked about Webb. 

4 financial situation in some germal ttmns witb the Resident 14 Q With the Clinton& you mean? 

s in the sense that you asked him - or he would ask you 15 A With the Clintons together or singly. I may 

6 “How’s Webb doing?” And you would say, “Not 50 well,” and in 16 have had a few more conversations with tfw: President 

7 part you meant by that fmancially not so well. 17 simplybecauseIseehimandspeaktohimmon:often. 

8 A I meant it in the holistic sense. Yes. 18 WithMrs.CLinton,itwasextranelynueandIdoa’thave. 

9 Q I think that’s what I just said 19 a memory of a specific conversation, other than at social 

0 A Yes. 20 functions, if she wouid just say in passing, ‘“I hope the 

1 Q Did you have any discussions with Hillary Clinton 21 Hubbells .&e okay,” and I would probably say, “They’re 

2 like that? 22 hanging in there.” 

3 A Not that I remember. No. 23 Q Okay. I’m going to try G ask you a couple of 

4 Q Did Hillary not ask how Webb is doing? 24 things that in my mind might have come up and you tell me 

5 A Just -- it would be literally in passing, it would 25 whxhcr it jogs your manory. ln my mind, it might have come 

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up that Webb would say “Let the President know X” or “Let 

Hillary know X” because he would know that you might talk 

with the President or with Hiliary. Did Webb ever say 

anything like that? 

A No. 

Q All right. Did he -- 

A Something that I don’t think anyone quite gets 

about him, Webb broke tlx law. He acknowlalp that. It was 

very separate from who he was as a figure in Whine and 

who he was as a friend, both to me and to the Clintons. 

He was and is very respectful of that friendship 

and of the position that his being a felon puts the Clintons 

in. He does not try to get messages to them_ He does not 

ask that messages be sent to them, nor do they ask that 

messages be sent to him. 

1 have all his notes from it, so you know when he started it. 

2 Q You can’t place a particular time on it? 

3 A I don’t remember the date. 

4 BY h4.R. EMMICK: 

5 Q How bad did Webb feel about what k had done and 

6 how it impacted the President? 

7 A I think he will go to his grave feeling that’s one 

8 of the worst things be’s ever done. 

9 Q And at any time, was k confiding in you those kind 

0 of feelings? 

This is an extremely politically charged 

envirmment under which k committed this felony and the 

way it has been played out. 

So he is extremely careful, cautious and very 

judicious in anything that he has to say or do about the 

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A Yes. I mean, we talked a lot about how hz felt 

about things. Yes. 

Q Did he ever convey to you ideas along the lines of 

you know, “I’ll never do anything like that again to ttu: 

presibeni” or “I’ll never do anything again that might hurt 

the President”? 

0 

I Clintons and he did not use me as a courier to get messages 

2 to and from the Clintons. 

3 Q Ill ’ ask the flip side of that. Did the Clintons 

4 ever, to use your phrase, use you as a courier of messages? 

5 And I mean even messages dong the lines of, you know, 

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A No. He doesn’t talk about it in that way. Webb -’ 

Q How does he talk about it? 

A Webb has to struggle with the gui& that he feels 

on what k’s brought -- the shame that k’s brought on his 

family and those that are. closest to him I don’t think Webb 

believes he’s ever going to be in a position to do anything 

onewayoranother. Idon’tthinkWebbevenseestbatkhas 

a future. 

Q Do you think he‘d be hesitant to do anything that 

Page 70 

1 “Let him know we still c3re about U” you know, Tell him 

2 to hang in there for us”? Anything like that at all? 

3 A They did not use me as a courier, but I always 

4 ~IdWebb~k~lov~~d~for~dI~~~ 

5 theasslnnptionthatIknewhisfriends,theystilllovedand 

6 caredfork 

7 Q Did you ever say to Webb things like, “The 

8 President was asking about you the other day”? 

9 A I might have. 

0 BY MR. WISENBERG: 

1 Q Did you ever complain to Webb, either directly or 

2 through Susie, that any of the actions he was taking or not 

3 taking in prison were hurting the First Lady? 

4 A I don’t think anything he was doing was hurting 

5 her,otherthananythinganybodydoesseemstohurtthem 

6 now. 

7 Q But that’s not the question. The question is did 

3 you convey to Webb Hubbell or to Susie Hubbell during the 

? time he was in prison, did you ever convey that something k 

1 was doing or not doing was harming the First Lady? 

I A No. The only time that I was really concerned 

2 aboutsomdhingWcbbwasgoingtodowaswhanbcwasgoingro 

s write the book and I thought that was ill advised. 

I Q Do you know when he was going to do that? 

5 A He started a book while in prison, I think you all 

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might hurt the Clintons again? 

A I think Webb is determined to lead a good life ant 

Iknowthatkbelieves~atkhasexposedallthatkknows 

andalIthatkisineverywaytbatiteouldk~and 

everywayitcouldkshownandthat~lsnothingmorcb 

show, tell or cxposc to anybody. 

Q Is another &y to put that that Webb feeIs Iike 

whatever damage k could have done to the Clintons k’s 

already done? 

A I~~f~ls~e~~~~~d~ 

people. 

Q Did you ever discuss with Webb his cooperation with 

our off&? 

A hitidy, when he was -letmesee-*would 

wr:haveevenbeendiseussingthat? Itwasmyw 

when he pled guilty that that was part of - I don’t hx~w 

what your tams are, but an agreematthatkreackd,that 

he would fully cooperate and it’s my understanding that 

k~thetiw:kpledguiityandthetimek~yw~ 

sentenced he fully cooperated with your office. 

Q And what did you talk with Webb about along those 

lines? 

A Just that, I mean, be was &pared to fully 

cooperate and that was the extent - I mean, I didn’t get 

into the specifics. I have not discussed the specifics of 

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Page 73 Page 7: 

I what Webb did cx didnt ’ do with him, even to this day. That I in Lake George, Arkansas, which is down tlx delta. I gl 

2 wasnotminetojudgehimon,thecourtsjudgedhimonthat. 2 there and I go to Memphis to visit friends. 

3 I wasn‘t really that interested in the specifics. 3 Q So you go back about once a month or you tq to go 

4 Q Were you ever planning to do anything to help Webb 4 back once a month? 

5 yourself? 5 A I by and there have been months where I’ve been 

6 A Yes. I let Susie -- I mean, I was really concerned 6 able to go two and three times in a month because either the 

7 about where they wuc going to live and their finances and so 7 Prcsidcnt’s gone and I’ve gotten to go back with him. You 

8 I gave them a house for the summer thatIwasinchicago. 8 all had me down there for a visit one time and I strung that 

9 They lived in my house for three or four months. 9 out so I could see my nephew. 

0 I had told Susie that she and the girls could move 10 Q How do you travel when you go back? 

1 inthehousewithmeandthatiftheyfeltW<etheyneeded 11 A Plane. 

z tbe house, they could have my house and I had a friend that I 12 Q Have you ever flown other than ~mmercial air back 

3 could go stay with. And that way, I tried to help as best as 13 to Arkansas? 

4 Icould. 14 A I don’t think so. Well, no, I’ve flown back with 

5 AndIwasindaily-asoftencontactasicould I5 the President. 

6 be with Susie. I used to go with her occasionally to see 16 Q On Air Force One? 

7 Webb. I kept her kids. I tried to be a f?iend. 17 A Yes. 

8 Q How long were they in your house? 18 Q Okay. That’s technically considered a military 

9 A I think three months, maybe June to September, I 19 plane, so let me ask this next question. Aside from Air 

10 believe. 20 Force One, have you ever gone back to Arkansas on military 

!i Q That would have included Webb, his wife and some of 21 transport? 

!2 the children? 22 A When Vince Foster died, we took the body back, but 

!3 A No, Webb was in prison at the time. 23 I didn’t go on that plane. I rode on the - no, I think -- 

!4 Q Oh, I’m sorry. 24 I’m trying to think. I think just on Air Force One or th 

!5 A It was Susie and the youngest daughter, Kelly, and 25 step-downs from that, the smaller planes. 

Page 74 Page 71 

I the middle daughter, Caroline. I Q Okay. Perhaps another - when you say the 

2 Q That would have been what year? 95 ‘ tkn? 2 step-down, not as prestigious as Air Force One. 

3 A ISthat Whenhf2WCZlttOpliSOll? YCS. ItwaS 3 A Well, tbey have -- occasionally, we have gone back 

4 the-yes. 4 and we’ve gone to Fame, Arkansas and thz airpor 

5 BY MR. BARGE& 5 there,Ithink,Qoesn”t-otHotSpriogSwfienwe’vegone 

6 Q He went to prison, actually, in August of ‘95, SO 6 backforfunemls,thosea@orts,Idcm’ttbinIc,accommodate 

7 wbenyousaytheywar:tbezefmmJunetoSeptemba;was 7 AirForceoOe. We’vetakentbeolderplanesthatinthepast 

8 Mr. Hubbell then part of the time? 8 waeoonsiderwiAirForccOIKbUttbev’lenotthebigp~* 

9 A ItwasthenextyKX. 9 Q Okay. So let’s first talk about the Foster 

0 BY MR. EMhXK: 10 funeral. TbereyoumightbavetakenAirForeeOneoroneot 

1 Q Itwouldhavebeenihenextyear? 11 the related kind of planes? 

2 A Thenextyear. ItwaswhenIwasinChicago. 12 A ItbinkwewentonAirForceOne,butwetookother 

3 Q So in ‘96, then. 13 planes down thzre for that funeral. 

4 A I’m sorry. Yes. 14 Q Okay. Now, my question to you about your own 

5 MREMMiCK: Sol,didyouwanttogetintoanarea? 15 travel, aside from the Foster fUneral, was there ever a time 

6 MR. WISENBERG: Yes. 16 whenyouwentbacktoArkansasthatyoufl~onamilirary 

7 BY MR. WTSENBERG: 17 plane other than Air Force One? Or a govemmen t plane, a 

B Q Since you’ve come up to Washington, how frequently ~8 non-Garcia plane other than Air Force One. 

P do you typically travel back to Little Rock? 19 A I don’t think so. No. I’ve driven. 

3 A I’vegotnewniecesandnephews,soIgobacLoftea 20 Q All right. -How often have you driven back? 

1 ifIcan. Iliketogoeverymanth,butIhaven’tbeenable 21 A on&e. 

2 to do that. 22 Q All right. And what was_tha? Was there a 

3 Q Do you usually go back to Little Rock as opposed to 23 particuhr purpose of that different than any other trip? 

Q some other place in Arkansas? 24 A Actually, I think I drove from Little Rock to 

5 A Little Rock and then I g0 -- my grandmother lives 25 Washington and it was because a friend was going to drive up 

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Q AIf right. But that was from Little Rock to 

Washington, not from Washington to Little Rock. Correct? 

A Right. Right. 

Q Al1 right. But you’ve got regular commercial 

airliners, you’ve got Air Force One. You don’t recall ever 

flying from Washington to Arkansas on an- other than a 

commercial airliner or Air Force One, except for perhaps 

Vince Foster’s funeral? 

A Yes. I don’t know. 

MR. WEENBERG: Okay. Thats ’ cd Ive ’ got on thal 

topic. 

MR. EMMXK: I’d like to ask a couple of questions 

on a different topic. 

BY MR. EMMfCK: 

Q Patsy Thomasson, how well do you know her? 

A We’ve worked together. I’ve known her for years. 

We were, I believe, in Washington together at the same time 

back in the late ’60s. 

Q You worked with her at White House Pasonnel for a 

time? 

A Yes. 

Q You were both deputies there, if I’m remembering 

right? 

A &3rIDZt. 

Q Does she still work there? 

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1 A Okay. 

2 Q Fii can you tell us what your home phone numbers 

1 A 

2 Q 

3 A 

4 Q 

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6 Q 

7 A 

No. 

Page 78 

When did she leave? 

About a month ago. Two months ago, maybe. 

where did she go? 

To the State Department 

Do you continue to have contact with her? 

I’ve seen her once since then. I think I’ve talked 

8 to her maybe twice. She’s traveled a lot. I’ve actually 

9 tried talking to her more, but I haven’t been able to connect 

0 withher. 

I Q ~you~~rup~d~~~~~~s~~ 

2 Department inuch? 

3 A That’s what I was SayhI& 

4 Q I’m sorry? 

5 A I’veonlyseenheron~ortwicesiDcesheleftand 

6 Ive ’ spoken to kr maybe once or twice. I’n tried to talk 

7 to her more, but I haven’t seen her tusz she’s been 

8 traveling. 

9 Q Is@.?. 

0 A And she’s too hard to get. 

I Q Do you have other friends at the State Department 

2 or is it just Patsy? 

3 A Lots. 

4 Q Lots? Okay. What I’d like to do is ask some 

s questions about phone numbers. 

3 are? 

4- 

5 Q Only one phone? 

6 A YeS. 

7 Q What about your work phone numbers? 

8 A Oh, I probably have three or four. Mine is 

9 m That’s the private line. My assistant’s tine is, 

10 I believe, M. We have a generic line, I think it’s 

1s. llxrernaybeoneorhvoothersthattheintems 

I2 use. 

I3 Q Do you have answering machines on all three of 

14 those work phones or on any of them? 

I5 A Yes. Yes. Now, that’s just my own little office. 

16 Presidential Personnel probably has -- 

17 Q I’m more concerned with the numbers for your own 

18 personal office. 

19 A Okay. Those are mine. 

!O Q Ail right. And there arc answering machines on 

11 thoselines? 

22 A I think there m answering machines on almost 

!3 every phone at the White House. I’ve neve checked, but I 

14 asume that most have them. 

IS Q Who answers these phones generally? We’ll star” 

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first with the private line. 

A Andletme-Ithinktheyall-allthoselines 

feed into each unit. 

Q ISee. ~~~gm~~t? 

A Likemyphoaehasrbtopabilitytopiclrupanyof 

tbosefourorfivelines. Ithinktheyalloperatothtsam 

way. I’veneverI&&ed. 

Q IguesS~tI’mtry&tOfiguIcOUtiSwith 

respect to the private Iinc, I take it it rings in your 

office? 

A It rings in both Offlces. 

Q who picks it up? 

A Depends. If its ’ a number I know, I pick it up. 

UFit’sanumberIkaowIdon’twanttotalkto,Iletther 

pick it up. 

Q Because you have caller lD on your telephones?. 

A yes. yes. 

Q AI1 right. And when you say the other phone, thal 

would be the assistant’s phone? 

A Correct. And there are usually three people in 

there, so any of the three could pick it up. 

Q And what about calls made from those phones? _. 

ls it generally the case that you make calis from your 

private line or do you make calls from the general line? I 

A Well, it depends on which button I push Depends1 

Page 77 - Pa@ 80 
3593 

on how many people afe talking on the phone which line I 

would use. 

Q So you co$d use the private line any time you 

would like to, but if no one is using the general line, yo 

could use that as well. 

A COneCt. 

Q Does anyone else use the private line, your @Vati 

Iinc, for making calls? 

A Probably. 

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2 15 A Unless someo&s there using the phone. 

Q What makes it your private line? 

A Not everybody has the phone number, so please don’t 

tell everybody tbat phone number. 

Q 0~ tips an Sded. 

A Well, I don’t know how good I feel about that 

It’s just - it’s the line I only give out to peopIe that I 

kaoW. 

Q All right. Same questions with respect to the home 

phone number. 

A It’s in tlnz phone book. 

Q Who else has access to that phone? That’s anothe 

way of saying who else lives with you 

A No one lives the besides me. 

Q So calls going in and out are going to be ca& 

from or to you. 

In re: Grand fury Proceedings 3-26-98 

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Q All right. I represent to you that there are 

records reflecting those calls. 

A To? 

Q To you. 

A To M-bat number? 

Q To - let’s see. To the number 0 

A That’s the generic number. That’s not wh3t I call 

my number. 

Q All rig&. Who else would she be calling there, I 

guess is the way to ask the question? We’re trying to figure 

out what those calls were about. 

A i don’t know who she knows there. she had gonea 

ta know my assistant, Whitney, because of playing phorx @ 

somuch. Letmethink. I’mnotsureWhitneywasstillthen 

then. ..Wlxm was the date of that? 

Q The 1 Ith of December. Two cafls, one right afte: 

tbe other, one at 8:36 in the morning and then one at 9:02. 

lt sounds like she was persistent, interested in calling 

someone. I’m not sure what it’s about. 

A Don’t have a clue. 

Q Who else on December I ltb would have been in 

position to take those calls? 

A wek other than my assistant, Caroline &Oft ma: 

have stilI been there. I can’t remember when the intern 

25 rotations were up. We had interns, but I doubt if there were 11 

Page 8: Page 8 

Right. Okay, Do you have a cell phone? 

No. 

what’s that numbe!r? 

I haven’t a clue, but 1’11 get it for you. I think 

1 Q 

2 A 

3 Q Do you have a beeper? 

4 A YeS. 

5 Q 

6 A 

7 its ’ out there in my purse. 

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Q Do you have a calling card for telephotxs? 

A N~.Oh,~~cuseme.Youmeanlikean~~&~card, 

not a White House caII.ing card? What do you mean? 

Q Either of thosc, actually. Any imaginable, 

conceivable calling cards for telephones. 

Ahhid+-yOUknUW,IchangethoseSeti~ 

evaytimetheygivemes43meh@ Ithi&I’mon-we&I 

think I’m on AT&T now. 

Q Is there some way that you can check as you checl 

for your beeper number? 

A Yes, I can find that out. 

Q Okay. We have records of two calls from Monica 

hwinsky to you on a particular date and I wanted to ask you 

ahout those. The date is December 11.1997, so that wouId 

have been at least three months or so after your discussions 

with her, the tail end of your discussions with her about the 

job. What were those calIs about? 

A I don’t know that there were those calls. 

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still intems there. We have volunteers. But that 

particular number, that &c numbe?, would have been 

answered by my assistant or an intern or a volunteer. 

Q Soitdoesn’tnecessarilymeanthatsbespoketo 

you and you don’t think she spoke to you at alL 

A I’m almost 100 perrmt positive she didn’t speak to 

me. This is thefirst I’ve heard of that call. I don’t 

n5memberacal.L 

Q Who do you know at the State Department that would 

caIl you at home? At your home. 

A We& any number of people. You want me to giv 

youali~ofw~~d~~~h~wo~d~~~ 

borne? 

Q Yes. 

A Okay. Seuztzy Albtight. Strobe Talbot. 

Mel French. Wendy He&ad David Pryor. John Baldridge. 

Elaine Shokus. Charles Stockton. Mike Ziteland. 

Q AII those people caIl you at home? 

A Absolutely could. I mean - 

Q Did they call you at home over tbe last couple of 

months? 

A Should we go over the w!oIe list again? I mean -’ 

Q whose number is associated withA &?9? 

Qbdrn-hmm. 

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Page X! Page 87 

1 .A That’s not a State Department number. 1 BY MR. EMMICK: 

2 Q It’s not? 2 Q 1 guess as 1 think about a question like that, I’m 

3 3 No. Theirs are 647. 

Q Whose number is 1_ 

3 thinking to myself even if I know ten people at the Stz 

4 4 Department. I would in genezal know which of them may hat 

5 .A I don’t know. Where is 429? s called me 15 times. I haven’t got that many friends tha, 

6 Q State h?partment. 6 would call me 15 times in a mon &. d 

7 A No. No. 647 is State Department. 7 A But you’re saying IS calls were made from a 

8 Q I’m only telling you what I hOW. 8 number -- 

9 .4 You’re guessing, too. 9 Q Yes. 

0 BY MR. WLSENBERG: 0 A -- to my house. 

1 Q To you, 429 is not the State Department? 1 Q Yes. 

2 A COneCt. 2 A And I have an answering machine. 

3 BY h4.R. EMMICK: 3 Q Yes. 

4 Q What is 429, as best you know? 4 A I may not have been there. 

.5 A That’s what I was asking you. I don’t know. I 5 Q Yes. 

6 can go look in my Rolodex and see what pops up 429. l’hat 6 A I mean, maybe my beeper wasn’t working. Maybe it 

7 number doesn’t stick in my head. 7 was someone trying to get me that way. 

8 Q Then let me ask the question a sIightIy different 8 Q But not 15 calls on OM: day, showing some 

9 my. During February, who would have been in a position to 9 persistence, one person trying to get a hold of you, they’re 

o call you at home in the neighborhood of 15 times? o spread over the whole month. 

1 A My mother. 1 A Oh, weII, you’ve Iost me. I thought you said I had 

2 Q Does s& work at the State Department? 2 15 calls in one day. 

3 A Someone from the State Department? 3 Q No, I’m sorry. Over the month. 

4 Q From this number, - 4 A Oh, I -- oh. I was trying -- okay. You’re saying 

5 A IfIknewwhatthenumberwas,IhetIknowthz 5 I had 15 calls from this number, _- _ - 

Page 86 Page b, 

I number, I could answer the question. I Q Yes. 

2 Q I’m trying to help, too. I’m just - our 2 A -- in a month period. 

3 information was that it was from the State Department. 3 Q Yes. February. 

4 That’s why I was asking those questions. 4 A There’s absolutely nothing unusuaI about that, 

5 A YeS, its ’ UOt, Its ’ OTK: Of the Other ageI&& 5 Igethtmdredsofcalls. SoifIknewwbothephonenumber 

6 ItsnottkStalcI)epartmtnt. ’ SOim-IkUOWtOOUUtZty ’ 5 was, then I could teIl you what it was. 

7 people. I don’t know how to help you. 7 Q Okay. So&z’IIhavetofigureitoutfromthe 

8 BY MR. W’ISNBERG: 3 number,notfromthef&quencyofthecaIIs. 

9 Q ih YOU 2tWttl-e Of tUly jXUklkU @lORC Line, @Olte 3 A Correct. That is a low number of calls. 

0 orphoneline,attheStateDepartaentthat’susedforLike 1 Q Okay. WhatI’dIiketodo1 sensitive political calls? I A ‘Ihere’ssolraepeopIeItalktoatIeasttwoorthra: 

2 A No. No. ! times a day in the different agenc%zs. 

3 BY MR. URGER: 1 Q In the State Department? Or you don’t know that 

4 Q A.ssxning it was a State Department number, who of i that’s a LXU from the State Department And you think it is 

5 the- i not 

6 A That’s not a State Department number. 5 A That’s CoITect 

7 Q I understand that. I said assuming it is - I MR EMMICK: what I’d like to do next, unless there 

8 A But it’s not. 1 are more calls that you’d Iike to ask questions about? 

9 Q Who at the State Department, if- anyoue, would have t BY MR. BARGER: 

o called you or did call you approximately 15 times in February 1 Q Would your Rolodex have that number in it? 

1 ofthisyear? I A I’m going to Iook 

2 A Idon’tknoww~calledmeuntilIknow~t L 

. Q How quickly would you be_ able to get an answe 

3 mumber, but one of my closest friends is Mel French wbo is I A I’ll try to find out today. x 

4 tbaeandifsomethinghadbeengoingonwithherson,we I MR. EMh4ICK: I’d like to turn to another subject 

5 could have easily talked. i am, it’s probably one that you knew that we were going to 

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Y .Y. -a-v M-J a .V”v.w---~U __a-- _ _” ..? &” I 

Page 89 Page 5 

I ask some questions about, and that is the Dolly Browning 1 A Mm-hmm. 

2 situation. 2 Q Do you remember any of the other agents? 

3 BY MR. EiiMICK: 3 A No. 

4 Q We understand e there was a reunion of the class 4 Q In general, can you give us your best estimate of 

5 that involved Dolly kjie Browning and the President and that 5 how many agents there were? 

6 you were there and what I’d like to do is ask you what 6 A No. 

7 happened at the reunion. 7 Q Were there more than ten? 

8 A Which part of it? 8 A I don’t know. Because they take a certain nun& 

9 Q I’m going to ask you in general and then, of 9 on the plane. 

0 course, we’re going to focus in on certain parts of it. 10 Q tight. 

1 First, could you describe the reunion? 11 A And tlxn they have a certain number on the 

2 A They wen? the class of ‘64, so what was it - it 12 ground. And they’re everywhere. I mean, they’re all 

3 was their 30th reunion? I guess it was the 30th And it’s 13 around the building, they’re in the building, tlzy’re 

4 the fust time, I think, that he had been back as president_ 14 in the room. So I truly don’t know. Dave is the one 

5 Hchrdgoncto~tbc~ionswhmh:bedbrmgovrmorand 15 I remember. I don’t know how many others there were 

6 itwasalargeoneandagroupofuswentdownandIthinkit 16 Q You described two days of the reunion. How many 

7 encompassed a two-day period. 17 events were there, if that’s a sensible kind of a question 

8 Q How many people attended the reunion? 18 I think of a two-day reunion as having a couple of events. 

9 A 1 don’t remember, but I think -- 19 ldontknowwhat~wotlldbe,butMewouldbcapartyand ’

0 Q Approximately. Was it thousands? A hundred? 20 one would be some other kind of thing, a sack race or 

1 A Well, I don’t - I’m a&&y trying to think of 21 something. 

2 that. I don’t remember how big the class was. Like three or 22 A The night before, there had been, I believe, a big 

3 four hundred people were in the class and they all brought - 23 reception at the hotel where tl~y had it. And we didn’t go 

4 I would say tbere m_yy$ere from five to six hundred 24 to that., 1 think we got in that morning and there was ar 

.s people there. Maybe. Or it could have been less. 2.5 event at the high school. *p”’ 

Page 90 Page 9; 

1 Q You mentioned that there were a number of people 1 Then a large group went to a favorite barbecue 

2 who went down thee. What did you mean by that? 2 place and filled up the place, they took it over, so what was 

3 A What I mean, the President went and then he has a 3 that - 30,4O people at least. 

4 groupoffriardsfromhighschoolthat~livebereand~ 4 Then the President and the student body off&s i 

5 allwentdownaswell. 5 tbeclass,Ithinktbeywentanddidsometb&andtbenthere 

6 Q M’howentdown? 

A Carolyn Staley, Bill Jamison &d I believe Dr. Jii 

6 wasthebigdimxxdancethatnight. Ithinkthatwasall 

7 7 Q Doyou~bexthz&tes,asbestyoucan? 

8 French. Ithink-Ithirikwealiflewdownwiththe 8 A No. . 

P President. 9 Q Do YOU remember the month that it occurred? 

0 Q Were there Secret Service agents in attendance, I 10 A No. Summer. Hot 

1 take it? 11 Q Okay. Did the subject of Dolly Kyle or Dolly Kyle 

2 A Always. 12 Browning crop up in conversations before the reunion? 

3 Q How many Secret Service agents were there? 13 A No. 

4 A Well, Idon’t ~~~w~y~~k~~ 14 Q What about what may have happened at the dinne. 

S We went down in one of the smaller planes. The detail could 15 dance with respect to Dolly Kyle Browning? Was she theze? 

16 A Yes. 

7 bepresentataUtimes,but wasthelead 17 Q DesuibewhatyousawwithnzpecttotbePresident 

8 agent on that trip. 18 and Dolly Kyle Browning. 

9 MR. WISENBERG: Pardon me a minute. 19 A Well, I noticed her - I’m trying to remember the 

0 MR. EMMCK: We’ve got a kxx&ing at the door. We 20 sequence of events. I can’t remember whether I noticed her 

1 all buzz around when that happens, 21 when they’fust took the pichue bemuse I don’t know -- they 

2 (Pause.) 2~ had a big group picture of evegbody. 

3 BY MR. EMMCK: 23 I remember her at the picture, but I specifically 

4 Q You were talking about the Secret &-vice agents 24 remember her in the ballroom. And I think that in that 

5 and you mentioned the name of one lead agent_ 25 ballroom area that whole event probably took -- we were 

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Page 9: 

probably in there about three to four hours, I think in 

that -- at some point in thaf they Went Off into a separate 

room and took a picture. 

I specifically remember her in the large picture, 

but I remember her in the ballroom itself and particularly -- 

1 don’t remember her when people were eating, but I do 

remember her dancing. And she caught my eye because of th 

way she was acting. And also the way she looked. 

She’s a large, tall - somewhat striking looking 

woman. And I think she was dressed in white, a white suit, 

a dinner suit of some sort. But what I remcmbfzd about her 

wasthewaysheactedonthedanceflooranditcaughtmy 

attention enough that I alerted the Secret Service and I 

alerted the advance people. 

Q Do you remember who you alerted of the Seeret 

Sel-ViCC? 

A Probably- He’s the only one I 

remember, but -- 

Q DidyoualertmorethanoneperxmfromtheSecret 

SeWiCe? 

A He’s the only one I remember, so I don’t - I don’, 

know if I did or not. 

Q All right. 

A I know there were more agents than Dave Carpenter 

thcrc. He’s the only one that I remember being there. And I 

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Page 95 

A Everybody -- the President was dancing with 

everyone and he had -- the tables were all -- the food was 

over here, the tables w-em here and then them was this big 

dance floor. And they had, I think, a disc jockey there. 

And the President had circulated through all the tables, hat’ 

danced with every single person there, and this was kind 12 

just this revolving kind of thing around the room. 

And Dolly was always within anywhere from inches to 

a few feet from him, but the way she did is she would be 

dancing with someone and say that’s the President there, S!X 

would start dancing up with her partner and then as soon as 

she got within a close distance, she would turn her back 

immediately and be dancing so that her back was to him, but 

getting closer. And she never got far from him the whole 

time. .. 

Whenever he was on the dance floor, Dolly Kyle 

would be right there, but she would have her back to them 

I don’t know if any of you have cats, it’s like eats do. 

They’ll come up and then they’ll turn their back to you. 

She was gaming him. It was - it was noticeable. 

Itwas- and part of this, she had on this real 

bright white outfit and most of the women there, I think 

were in black and red Red’s an Arkansas color. She was 

always circling him. And it caught my attention and I 

started watching her. 

Page 94 

talked to the lead advance, our trip director. 

Q who was that? 

A About her. I think it’s - his last name is Bihar, 

B-e-h-a-r. I’m just blank. I think it’s Steve Behar - 

what’shisnamc-rmdtficntbcotherpersontbatItalked 

toabouthcrwasPattyKreiner,whoactuallycameuptomc 

andtalkcdtomaboutDollybezauschcrbebaviorwasso 

unusual. 

Q WhoisPattyKreiner? 

A JUROR: Could you share with us that weren’t 

there about this behavior? Because I’m kind of in the dark. 

I’m hearing about all these people - 

w. EMMICK: In fact, we’re about to get to exactly 

that. I was trying to bracket the situation fvst 

BY MR. EMh4ICK: 

Q Let’s jump right to it. What did -- 

A I’m sorry, you asked me something right before 

that. Who was Patty Kreiner? 

Q Yes. who is Patty K&IX%? 

A She is -- I think - she’s a chssmate of President 

Clinton. She’s from Hot Springs and she had been his - I 

think his first press secretary when he was fust govenlor. 

I believe. In that frrst term. 

Q So you saw Dolly Kyle Browning doing something that 

struck you. What was that? 

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And then Patty Kreiner came up. Patty, I guess, 

knewbafromhighs&c~~L Ididn’tbrowwboskwasatthat 

point And at some point in there, I pulled the President 

aside and I said, “Arc you watch& her? Are you watchiag 

that woman? Who is she?” 

And I think that’s when he told me it was Dolly 

Kyle, that he kn& her, had grown up with her. 

Q Had you heard of her name befog? 

A Yes. Ithink runcmbcrherfromtk’92campaign 

Shehasab~~orabrotherandasisterthatlivein 

Little Rock, I believe, and I don’t know tbcm and I didn’t 

knowber,buttberewere-Dollybadbeenhawkingabcok, 

~ngtowritcabookandIdoo’tknowwhdbcrthathadcomc 

upinthe’92campaign,butatsomepointIknewaboutbrrir 

the context of some book that she had wanted to write. 

Q And so for you, it meant something for the 

President to say “That’s Dolly Kyle”‘? 

A No. It just - that didn’t - no. It didn’t 

register with me later, until later. 

Q I_hrtil later, you mean? 

A Until later about her connection, but it was just, 

“No, that’s Dolly Kyle. Sbc’s from_heFe.” It was just - I 

mean like just this brief kind of thing, “Oh, she’s okay kind 

of thing.” And I said she is acting -- she was acting really I 

bizarre. So he brushed it off. I 

Page 93 - Pa@ 96 
3597 

1 Q Okay. WLn you say hc brushed it off, I’m It was she got right up to him and then if he 

2 going to ask, just before that she had been dancing that 2 turned in her diEtion, sbe immediately turned her back and 

3 way with him, was tbe F%esident acting disapprovingly of 3 stayed, though, within his eyesight. 

4 that? 

S A I don’t think he noticed it. He was - the 

6 President fully focuses when be’s talking or whatever be’s A I didn’t see him noticing it because he was ta&.in] 

7 doing. I don’t think he was seeing this, because he was 7 and dancing. I noticed it I brought it to his attention 

8 always surrounded by his partner and dbers or - and, you 8 and also it was brought to my attention by someone else. So 

9 know, after they’d stop dancing, there would be a group 9 I alerted other people to start watching this woman. And we 

2 people. 

Q And what did you watch her do? 

A Continue to do that. 

4 Wheneverhetraveis,behassomeone A And this went on and at some point, this I’m not 

5 person. It’stbepersontbatstandstberetotaketheaotes, 15 clearoa,ofwhomadetheactualcantact,butatsomepoiaf 

6 togethimwater,tOjuStm~sureyou’~tbereIf~weds 16 I can’t remember whether the President approached her or 

7 something done. I knew all these people or a lot of the J7 whether she finally made contact with him. 

My gist of it is that he spoke to her, said 

9 role. 19 samethingtoher,andthenIthLaksfienunedawayandthen 

:O And the Secret Service, if he was dancing, remanber was seeing her face, 

Q Did she appear to be happy or unhappy or - 

1 witnesssaidtheywen:“nofu&erihanyouandI;shc I Wk3berdemamrallthmughthis,wasnotlikeevuy 

2 refemncing the grand jury forqerson, not Mr. F!mmick, and 2 eke, smiling and hgbiug. Sk was saious. Her expression 

3 that’s basically the length of our table. 3 wasveryseriousexrytimeIsawhernearhim. 

4 THEwlTNESs: Thankyou. Q hui youre ’ still, youre ’ watching from a distance. 

5 Now I’ve forgotten what you asked me. A I’mwatching-ye& 

Q From a short distance. 

7 BYMREMMICKZ A Fmmav&yshortdistance,butalotofpeopleare 

8 Q Let’seallitso~between12and15feet. 8 c0mpactinthisanza. 

9 Something like that. Q And what’s the President doing at this time? You 

0 A Yes. At tkmost. And they were always - 10 mentioned that she was looking serious or angry. 

1 Q Tenfm? Allright. Tenfeet A When she stopped - and I’m not sure about this, 1 

2 A what‘ were you asking? 12 don’t~owwhetherbehadousedhertostoporwhethasfK 

3 Q Yes. Youmentionedtbatsbewasdancinguptobim, 13 stoppedaadthenIsawthatfiewaslookingatherandthey 

4 turning around and perhaps dancing away or something like 14 started to speak. 

5 that_ At that point, I walked up and got next to him or 

6 A Yes. 16 as -- there were stili a Iot of people, I just started 

7 Q You noticed that - 17 standing tIX?lC 

8 A I’d say she was gaming him. 18 And I don’t remember what they were saying, 

9 Q Gaming him. I’m not sure what you mean, so you’ll 19 but this aU took place very quickly, and he then turned 

0 have to exphiin. 20 tomeandsaid,“Ineedtotalktoher.” Andfsaid, 

1 A My interpretation of watching her was she wanted .21 “Okay. Whertz do you want to do that?” And he said, 

2 so~tonotice-shewantedhimtonoticethat,butshe 22 “Well, fmd us a chair.“ 

3 was doing it in a way of not - everybody else, you know, 23 So I immediately - and there were people all 

Q they were hugging and, oh, you know, telling old stories and 24 around fbem, it wasn’t just the two of them, them were a 

5 stuff, but she never spoke to him. 25 number of people standing thez. So I don’t know whether 

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I alerted Steve Behar, but I think I did. I said, “We 

need to get a place for them to sit.” 

And I also said to Steve and to the Secret Service 

at that point, because I told Dave that the President’s going 

to come over and have a conversation sitting over here. I 

told them under no circumstances is she to leave this room 

with him, I want you to watch her at all times. I’m veq 

unquotable with her. 

So we pulled up two chairs to tbz side of the room. 

They were kind of -- there were pillars on the side of thr 

room, sort of under that part. 

Q Well, what were you concerned about? 

A Her behavior was strikingly bizarre. 

Q I’m trying to figure out -- maybe so, but I’m 

trying to figure out what were you couczrned that she was 

about to do? 

A I wasn’t sure. She was angry. That I knew. And 

she had been acting weird all evening. And Patty Kreiner, 

who did know ha, had come up to me and had told m somahing 

to the effect that this woman, she is a nut case, what is she 

doing around him, are you watching her. Patty knew her, I 

thinkknewherfanlily,Icnewher. Sothalwasauineeded+ 

Q When you said to the Secret Service or to someora 

else under no circumstances should she leave with the 

President, what did you mean by that? 

Page 102 

I A Just that, that when we got ready to leave or if be 

2 ~~getup~dl~~~~not~~~o~~fo~ow 

3 himoutofthatrooln. 1wi3ntedIlerillsightofeverybody, 

4 contained in that room. !30 I conveyed that message. 

5 We pulled up two chairs and, if I remember 

6 correctIy,thePresidentsatfacingouttowardsthemomand 

7 IthmkDolIy’schairwas ~of~~ebut~~~ 

8 backmainlytotheroom,sothathecwldseethe~oleroom 

9 and we could see l&n, but she didn’t - I don’t think her 

0 vision was out into the room. 

1 Q How close were the closest people to the two of 

2themthm? 

3 A There were tables. I stood probably within - 

4 never further than from Mr. Emmick and I and oftentimes I 

5 stoodrightbehindber, Istayedwithin6 Q And I’m about six feet from you? 

7 A Attbemost. Yes. Istayedwithin-sometimes 

6 ma1 good earshot and some&esjustsoIcouldhearthetone 

9 rather than the actual words. 

D Q Was it loud in the room? 

1 A Attimcs. ~,whowastheSecret 

2 Service agenk had to be. also positional somewhere. I was in 

3 closer, Dave was somewhere, but I don’t remember where, but 

4 he would have been there again within whatever their - I’m 

6 sure they have a distance that they’re not supposed to be 

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further than, I just don’t know what it was, but he was 

around. 

Steve Behar walked in and out of that. Other 

people in the room would have been as -- let me 966: if 1 can 

remember. There were tables over here, there were people 

always walking around. So probably the nearest table couid 

have been six or eight feet away, if that. 

Q I guess what I’m trying to figure out is who woulc 

have been within listening distance, earshot. 

A Me. 1 was. 

Q Okay. Anyone other than you? 

A _uld have at times. Steve Behar 

could have at times. There were a number of people that cam 

up and stood with me, chatting with me or chatting with each 

other that could have also heard 

It was not a - there was no effort to make this a 

real private conversation. It was in the middle of a veq 

large event in a large room. It’s just that they were a 

little isolated off to the comer. 

Q Semi-private, I guess. 

A Yes. I mean, just for a place - I mean, once he 

sat down and engaged in conversation with her, I made sure 

other people didn’t interrupt them and kept it somewhat 

clean. 

Q All right. Then what happened? What did you see? 

Page IL 

What did you hear? 

A My memory of that was Dolly was reaIly agitated 

withhimandwasraisinghervoice. Thegistofwhatshcwar 

sayingtohimwashowangryshewasathimfornothaving 

beenherlover. ThatwasthebottomIineofit. Shehad 

beeuinsovewithhimsincttbcy~kids. HekncwsheW 

beezxinlovewith%m. AndhehadxeallyQ That’swhatsheissayingorA That’s what she. is saying. Sh= did most of the 

talking initially. In fact, almost all of it. And he was 

just looking at her listening, is my memory of that first 

piece of it. 

And she was telling this tale of having been in 

lovewithhimsineetheywemki&,thathehadminedher 

life by not reciprocating; that she did not understand how he 

couidhavehadthis~~with-_sbcwasy~about 

Gemlifer Plowers. 

HehadhurtherinwarsthathcwouidnevaInrow; 

hecausedhergmatmisuy;andalIbecausehehadaotbeen 

her lover and he knew how much she had loved him; that she 

had fallen on hard times; she needed money. 

At some point, she started-tang to him about 

thisbook. Shetoldhimshcwastryingtofmdapublisher 

and was having a hard time. 

The conversation had -- I don’t mmcmbcr literal, 

Page 101 - Page104 
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In re: Grand Jury Proceedings Mull 

Page lo! 

1 but it had UPS and downs and she would get really a&ted, a 

2 little bit louder, and theu she would tend to calm down, 

3 little bit and aotually get fairly reasonable and then she 

4 would go from “You’re the wnrst person I know, you II&MA my 

5 life” to “I how you’ve been there for me, my family loves 

6 you, you’re really my friend.” 

7 And then when he started talking to her about this 

8 that’s when she -- he let hez rant and rave, is what I would 

9 call it. 

1 0 Q What was his reaction to this ranting and raving? 

1 1 A My memory of this was he was listening intently to 

1 2 whatshewassaying. ~e~dnot~v~rn~h~f~~d 

1 3 then he -- after Sk sort of got over this first sort of 

I 4 volley, he was going “Dolly, you know that’s not true.” 

1 5 Q It’s not true that what? 

1 6 A Well, just the whole gist of what she had just 

1 7 said. I mean, her dumping cm him about this supposed -- you 

1 8 know, love affair and - 

1 9 Q I’m just trying to figure out what wasn’t true 

2 0 about what she was saying. 

2 1 A Dolly -- 

2 2 MR EMMICI(: We’ve got a knock at the door. Hold 

2 3 on, 

2 4 THE m: It was not true that he had ever hur 

2 5 her, had done anything - 

Page 106 

1 hat. EMMKX Hold on. 

2 (Pa==.) 

3 MR. WISENBBRG: &r-y on. 

4 MR. BhibGcK: Do we have lunch? 

5 MR. WISENBJZRG: Lunch is here. Carry on. 

, 6 THE ~~NESS: It wasn’t true that he had ever done 

7 anything to intentionalIy hurt her and when she started 

6 talking about the book in the book, she was going to 

t 9 allege - and she said, “‘Ibis is going to be really about 

11 D you.” And she said, “And I need money and I’m going to tell 

1 1 people that we did have an affair.” 

1: 2 He said, “DolIy, that is just not true.” And he 

1: 3 was tdcing to her, “Why are you wanting to do this?” 

1d 4 She talked a Little bit, I believe, about her son. 

I! 5 BY MR.. EMI’ACK: 

l( 5 Q Well, what was his manner when he said that to her? 

1: I Was he furious at her? Was he matter of fact? 

11 3 A Listen,thiswasawomanwhoseemedonthevezgeof 

I! ? going out of control. We’re in the middle of -- 

2( 1 Q I’m just asking a question. 

21 I A No, I’m answering it. We’re in the middle of 

2; z three. four, rive hundred people. He was staying extremely 

2: 1 calm with her. Its ’ the same way that I think anyone would 

2r 4 talk to someone on the verge of hysteria. This is also 

21 5 someone he knew. 

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He stayed calm. Yes. 

That was my question. 

He stayed calm tbrougb all of this. 

All right. How did the conversation progress? 

Well, that’s the gist of it, what 1 remember of it. 

Eventually, she got calmer and calmer. I, on a couple ( 

occasions, tried to end it. 

I know two or three times I went up to him and 

said, “Mr. President, you have other friends here, don’t 

you think it’s time to go on and mingle with the crowd: 

He’d say, “No, no.” And this is me whispering in his ear 

andhistumingtome. 

. 

Q 

what 

A 

Q 

A 

Q 

that. 

A 

Did the Secret Service exhibit any concern about 

she wag saying or doing? 

No, but they wouldn’t. 

lky didn’t? 

They did not. I don‘t remember that. No. 

They didn’t alert, crowd closer or anything like 

No. No. 

MR. EMMICK: Sol, you had a question? 

MR WISJZNBERG: If I could just summa&~, and tell 

me if I’ve gotten anything wrong, before the conversation, 

we’re talking about Dolly -- what’s her fti name? Dolly 

Kyle Browning? 

hfR.EM?&IC~ Right. 

Page 101 

TH.B WIRIESS: I know her by Dolly Kyle, the 

Browning part I’ve mad, 

BY MR. WLSENBERG: 

Q Okay. Dolly Kyle or Dolly Kyle Browning, she’s 

first-befomtl%yhavethe;versati~s~’s-as 

you’vedesai~gaminghim. Duringtheixmvelsati~at 

some point she’s on the verge of losing control. 

She acknowledges that he’s never been her Iover, 

thOUgh*‘SdwaySWantedhiXlltObe;sbestatesthtishe 

needs money and she states she’s going to write a book 

alleging an affair - 

A Shehaswrittenabook. 

Q Shes ’ written a book alleging an affair, even 

though there wasn’t one. Is that a fair summary of-what 

you’ve told us? 

A yes. 

MR. WISENBERG: That’s ah I have on that line of 

questioning. 

h& Ehfh%XCK: Are there questions you had on that: 

TKE KIREPEBSOM IZxxcuse_~. I~s~f~I~ch. 

MR. WISENBERG: What I would like - 

THE FOREPERSON: lf you have just maybe one more 

question, but - 

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1 MR. WISENBERG: Actually, we don’t, but what I 

2 would like to do is ask the witness to step outside for 

3 about -- we don’t j&t have one, in other words. So I’d like 

4 the witness -- 

5 THE FOREPERSON: That’s what I kind of figured. 

6 MR. WISENBERG: Yes. If the witness could step 

7 outside for -- actually, I think we’re through with the 

8 witness for now, but if before we start lunch, if we could 

9 have like a 60-second conversation with the grand jury? 

0 THE FOREPERSON: SUre. be. 

1 MR. WISENBERG: Okay. I’ll ask -- I’m sorry, go 

2 ahead. 

3 MR.EMMICK: Iwa~juSt gOiIIgt0 say,so if you 

4 would step out for just a minute or two, then we’ll be right 

s out to let you know what the status is. 

6 MR WISENEIERG: We’ll come and chat with you and 

7 your lawyer. 

8 THE WITNESS: Okay. 

9 (The witness was excused at 12:37 p.m.) 

0 (Whereupon, at 12:42 p.m., a luncheon recess 

1 wastaken.) 

2 - ***** 

Page 11C 

1 AFTERNOON SESSION 

2 (1:48 p.m.) 

3 MR EMM~QC~ Let the record reflect the witness has 

4 reenteredthegrandjurymnn. Dow?haveaquorum,Madan 

5 Foreperson? 

6 THE FOREPERSON: Yes, we do. 

MR.EMMICk~tbere8ny U1¶ZiUthOIiZdpas0nSiLI 

thegrandjuryroom? 

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THE FOREPERSON: No, there are not. 

Ms. Scott, I need to remind you that you’re still 

under oath. 

THEwITNEss: Thank you. 

BY MR. EMMICK: 

Q I think when wc stopped last, you were talking 

about the Dolly Kyle Browning reunion situation, and, if I 

recall, you were sort of at the tail end of the principal 

discussion of that_ You were talking about what she WIE 

saying to the President, how the President was somewha 

impassive about it. 

I wonder if you can tell us - 

A He wasn’t impassive. He was cahn. 

Q All right_ Calmis fine. Canyoutell us bow the 

conversation progressed? 

A I thought I did. Where are you unclear? 

Q I was thinking you were toward the end of the 

? 

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Page 111 

conversation, but they hadn’t stopped talking yet. 

A I don’t remember how it did exactly end. I don’t 

know whcthcr finally I told him that we needed to rcjr 

others or others came up, but at smne point it stopped, the 

conversation stopped. 

Q How long were the two of them talking to one 

another in the semiprivate area? 

A I’d say anywhere from 25 to 40,45 minutes. 

Q Okay. Quite a long time, it sounds like, in 

proportion to the three or four hours of the reunion. 

A I didn’t take it that way, but you could 

characterize it as that if you wish 

Q What happened as they parted company? 

A He reengaged in the room, and I don’t remember 

seeing ht? after that. I don’t larow - I don’t know where 

she ended up. I didn’t notice her after that. 

Q What was the last part of their conversation about 

A I don’t remember exactly. I remember she was 

quieter, calmer. I think I said to him, “Is everything 

okay?” He said, “Fine.” He seemed fine, relaxed. She 

seemed relaxed. 

I don’t -- I’m sorry, I don’t remember anything 

other than kind of the tone and my impressions of it. 

Q He rejoins the rest of the group. She disappeared, 

more or less? 

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A I just didn’t notice her anymore. 

Q Did you stay within that relatively short distance 

ofthePresidentfort.herestoftheevening? 

A h’Im-hmm,yeS. 

Q Is that because of anything pertaining to Dolly 

Kyle? 

A It’s my job.%ven when I - I danced, I think, two 

orthreetimes,andIalwaysdzmczdkindofrightnearnearby. 

I was there offGaIly, not as a member of the 

reunion press. 

Q About what time of night did the reunion, or that 

part of the reunion end? 

A Idon’tknow,butitseemedl&-Iguessitwas 

sometime after midnightQ Did you have occasion to speak with the President 

about Dolly Kyle Browning sometime after that? 

A Wedid. Thatevening-Idon't xemembertitber. 

wedidornotbecauseagroupofus-sevenofuswent 

upstairs to his suite, and we played cards probably until 

3:00 or 4:00 in the morning. And we were joking and eatinp 

and - I don’t know whether she evy_came up then, and she 

could have, because a lot of people noticed her. 

Q Who were the seven people? 

A Dr. Bob Asphall, his wife, Marya Asphall, who’s a 

Psr?e 109 - Pare-T12 
3601 

In RX Grand Jury iroceedings ’ Multi-Page” 3-26-98 

Page 113 Page 11. 

1 psychologist, Joe Newman, David Leopolous, Carolyn St&y, 1 “What was that about?” 

2 Phil Jamison, Dr. Jim French, and -- did I say Joe Newman? 2 A I’m sure I did, and he said, “It was weird, wasn’t 

3 Q Yes. 3 it,” that kind of thing. 

4 A And myself. 4 Plus, there wasn’t a need to talk a lot more about 

5 Q All right. You mentioned that the topic of Dolly 5 it because I was very aware of what had gone on with her. 

6 Kyle might have come up, but you’re not sure if it came up in 6 Q And he thought that you understood all that you 

7 tlxcourseofthecardgame? 7 needed to understand about it? 

8 A Right. 8 A Yes, I did. My main thing with him is, I wanted to 

9 Q But I thought you said at some point you did talk 9 know if he was okay, if he was unsettled by that, and, you 

o with the President about it. 10 know, 1 was -- I thought the woman was an absolute nu 

1 A Idid 11 He seemed okay about it. It seemed to have gottc 

2 Q When would that have been? 12 resolved. They parted. She didn’t - I didn’t see her 

3 A I don’t remember whether we did briefly on the 13 again. I knew what I knew and was comfortable relating that 

4 planegoingbackorwhetheritwaslaterwlxmwegotbackto 14 ifIne.ededto. 

5 Wa&in@m,butIthinkit-I’mfryingtorememberwhether 15 Q -Did you write down notes? 

6 he mentioned it that night. 16 A I did I wrote down my impressions of what had 

7 At some point he suggested me that I should write 17 happened. 

8 downtit1 remember of everything Dolly said and did, and 1 18 Q Did he as well? 

9 said I would do that. But I don’t nzmembex whether we did it 19 A Hedid 

!o thatnightorontbeplanegoingbackorwhenwegotbackto 20 Q Did you have any later conversations with the 

II Washing-ton. My -- I just don’t have a memory of *&at. 21 President about this incident? 

!2 Q Did he-say why? 22 A I don’t think so. I think once -- once I had given 

13 A Yes, because it was a bizarre conversation. I 23 him those notes, I don’t -- I don’t think we talked about 

!4 thought it was bizarre, he thought it was bizarre. Her - 24 that since then. 

!5 Q Even so, you don’t always write down notes about 25 Q How long after the reunion did you actually write 

Page 114 Page 116 

I everythingbizamzthathappens. Wastberesomeconcemthat 1 those notes up, and how did you give the notes to the 

2 he had that prompted that? 2 President? 

3 A Wel&Ithinkbecauseofthenatureofthe 3 A That’s the part I can’t remember. IthinkIwrote 

4 conversationandthefactthatshebadbeenthreateninghi.m 4 itontheplanegoingback,andIthink-IthinkIgave 

s allthroughtheeonvexsation,andskwdsthrcateniagtogo 5 themtohimontheplane,butI’mnotsureofthat. Icould 

6 publicwithalie,andshewasthFmtcningtodowhatev~sbc 6 justaseasilyhaveeomehomc-OreomebacktotheWhite 

7 hadtodotogetmoney. Ithinkthatwascauseforumarn. 7 Houseandwritithem. Butmysmseisthat’swhatIdid 

8 Q Is that what the Resident said? 8 Q Was there any discussion about what had actually 

9 A Thats ’ what I heard. He was concerned - I mean, 9 c~cumxl tbx? You know, how soa&mes we’ll talk with one 

o he heard what I heard We heard the same thing. IO another in order to remind each other what was said. 

1 Q No, no, what I mean is, is that what the I?tCkkIt I1 A No, no. 

2 said about the xcason you should put it to notes? I2 Q Okay. And no other conversations about that 

3 A Hewaswoniedaboutwhatshewasgoingtodo,and 13 incident with the President since that time? 

4 htthought,tobesafe,weoughttoeachrememberasweheard 14 A No. 

s itandsawit. 15 Q Any discussions about Dolly Kyle Browning in 

6 Because here’s a man that already been the subject 16 general with the President since that time? 

7 of other people telling tales about him, and this was at 17 A I - I don’t even - I don’t even think I discussed 

8 least an opportunity that if someone -ifDollytriedtogo 18 it with him since she’s resurfaced. I don’t think so. 

9 public with this, we could refute it. Because she’d already 19 Q Any discussions with anyone else about that 

10 made known what she wanted to do, and we had - I felt like I 20 incident? 

II hadhandlcditaswellasI~howtohandleifandsohad 21 A Theonly -- right before - when I was asked to; 

12 hc,andthiswasagoodopportunitytobcabletoreally 22 comebere,Ihadreadinthepaper_fhatoneofthethingsyou 

13 refutexmx&ing,ifshewentfonvardwiththisasshewix 23 all were going to ask me about was Dolly, and I hadn’t really 

14 threatening to do. 24 thought about her much. 

15 Q Did you ask him any more general questions, like, 25 And so I went to Bruce Lindsey and asked him, 

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‘Bruce., did you know that I wrote notes after that incident?” 

And be said, “Yes.” He said, “In fact, I think we’ve -- I 

got a copy of that.” And I said, “Well, did you turn those 

over to the independent prosecutor?” And he said, “Yes.” 

I said, “Well, I’d like to see what I wrote,” and said, “I 

don’t remember.” 

So he dug them out So before I came down here the 

first time I quickly looked at them. 

Q So your conversation with Bruce would have been one 

time you talked about the reunion incident, let’s call it, 

with someone other than the President. 

Have you talked about that reunion incident with 

anyone else? 

A Other than that night, we may have joked about it 

UpstairS. 

Q When you say “upstairs,” what do you mean? 

A When we were playing cards. I don’t have a memory 

of that. It would have been logical that we would have if it 

had come up, but I don’t remember the President ever bringin 

it up. 

Q What about in Washington? 

A No, because no one up here, I think, knew about il 

~~stheywereattherelmion,andIwastheonlyperson 

that was there other than the staff -- other staff. 

Q Recent events haven’t caused that subject to come 

Page 118 

1 up between you and anyone else? 

2 A Contrary to what a lot of people think we don’t gc 

3 around gossiping and talking about all this. Too many people 

4 get subpoenaed for imagining or even thinking they’re saying 

5 something, so people don’t talk about these things, they 

6 don’t talk about them. 

7 Q That SOUndSlike ano. 

8 A It’s a no. 

9 Q Have you over&aid anyone else bring up the subject 

o of Dolly Kyle Browning at any time? 

1 A Anybody in the White House? 

2 Q Yes. 

3 A No. 

4 Q Anybody outside tlx White House? 

5 A Everyone, when they fmd out you work in the White 

6 Hou~c,tbcy’llgo,“DoyoukmwMonicaLewinsky? Doyouknow 

7 Linda Tripp? Did you know this Dolly Browning?” 

8 And, unfortunately, I say, “Yes, I’ve had the 

9 misfortune of knowing ail those people.” That’s the extent 

0 of it. 

1 Q !SonobodywhoactuallyisattheWhiteHouse,bu 

2 others outside the white House. 

3 A COmXt. 

4 Q Okay. Did you talk with Hillary Clinton about it? 

5 A No. 

3 THE u'rnEs: I have one question. Who’s that man 

4 that has been sitting there? 

5 MR. EM%~~CK: His name is David Barger. 

6 THEUlTX3S: Okay. who is be? 

7 MR. WFGENBERG: He’s an attorney with our office 

8 THE mws: Okay. 

9 MR. EMMICK: He’s not an unauthorized person. 

0 THE ~ITNEX?: Okay. 

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MR. EMMICK: Sol, any questions you had? 

MR. WENEERG: Not on that subject 

MR. EMMICK: Okay. 

A Let me turn to another subject then. Well, before 

I leave 1% has anyone written anything else, as far as yoi 

know, about the DoUy Kyle Browning incident, other than Ux 

notes written by the President and the notes written by you? 

A Not to my knowledge. 

Q Any e-mails, any letters, any summaries, anything 

like that? 

A No. 

Q Let’s talk a little about Martha’s Vineyard. 

A Okay. Martha’s Vineyard? Okay. 

Q There’s a saloon called The Black Dog. 

AUh-btlh 

Page 119 

1 but .afsmx: Sol, any more questions you wanted to 

2 ask about Dolly -- 

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Q And we were curious whether, when the President 

bought some items from The Black Dog, how those got 

distributed, whether you got any of the items. 

A I don’t know The Black Dog saloon. I’ve beard 

aboutit Nmrbaz.ltoMartha’svineyam. AndIdc4l’tkaow 

bow they got distributed 

Q Did you get%y items? 

A Idid 

Q Okay. !3o you know that at least some items got 

distributed to you. 

A I know what he gave to me, but I don’t know how 

items from them got distributed. 

Q Okay. Tell us what you know about Black Dog items 

coming from the President to you. 

A Well, I didn’t know they were Black Dog items. I 

gotaswea&rtkindofthingthathasanemblemofaIittIe 

black dog on it 

Q Okay. 

A Ihadnoideathatthatwasthesameuntilthere 

wasanewsshowaboutthatplacc,andthat’sthcf~timeI 

actually saw that that was the logo and that that was 

actually on something that I had,_ 

Q It didn’t say “Black Dog” under it, it just had a 

black dog? 

A I don’t think it does. I think it’s iust the face 

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1 of a lab. 1 year. Then it was shortly thereafter that we stopped having 

2 Q Okay. When did you get that from him? 2 tkm because they just got too large, or at least 1 stopped 

3 A That was one of a couple of gifts that 1 got at 3 attending them, and 1 don’t think they had them. 

4 Christmas. 4 So all through the next year we didn’t have them, 

5 Q So it was like a w-rapped gift and the whole thing 5 that 1 remember. 

6 as part of a Christmas celebration? 6 ITIE FOREPERSON: Were there ever any dinner parties 

7 A No, he told me this was something that he had 7 or gatherings that you can recall where many of the people 

8 gotten before, but it was part of Christmas gifts that I got. 8 from the Arkansas dinners were, where it could have almost 

9 1 think he intended it that way. 9 been called an Arkansas dinner, but not really -- and thi 

0 Q Was there any other discussion of The Black Dog at 10 was afta Web Hubbell plea&d guilty to the offense at the 

1 all or anything like that? 11 Rose Law Firm -- where people were openly tallring about 

2 A No. 12 things they could do to help the Hubbells? 

3 Q Doyouknowanytbingaboutanyoftheotheritans 13 THE WlTNESS: What - what is referred to in NIX? 

4 obtainedbytheClintonsatTheBlackDog,wheretbeywent 14 prers and what I’ve beard talking about the Arkansas nights, 

5 to? 15 that stopped in that first year. That did not go on beyond 

6 A No. 16 that. 

7 h4R. EMMKk As I recall, there was a question 17 My circle of fi-iends are the Arkansans. There an 

8 about Arkansas dinners. Did you want to - 18 few people outside of that. So - but I’ve never heard that 

9 THE FOREPERSON: Yes. During the time that Mr. 19 term “Arkansas dinner” or “Arkansas parties” ever applied, 

3 Hubbell was working at the Department of Justice, did you 20 except around that first group of dinners that we used tc 

1 attendanyoftheArkansasdinnersthathappened,Iguess, 21 have where we’d go out to a restaurant, 

2 every month or every couple weeks or so with all the people 22 THE FOREPERSON: h,fdxnm. 

3 from Arkansas? 23 THE WITNESS: Now, all of us entertained, and 1% 

4 THE FITNESS: Tuesday nights, yes. 24 certainly entertained, and, iu fact, when he was going to 

5 THE FOREPERSON: Okay. Did you attend them many of 25 prison, I threw an anniversary party for Web and Susie at rn) 

______--- 

Page 122 Page 121 

I them, most of ti? I house, and a large number of people came. 

1 MR. EMMICK: We have a knocking at the door. 2 I am sure that people were talking about Web and 

5 THE FOREPERSON: Oh, okay, all right 3 Susie and their condition, but I don’t know how that fits in 

I (Inttzmlptiol.l to plIxe4ings.) 4 the context of your question. 

5 THE FOREPERSON Did you attend many of them? 1 5 THE FOREFERSON: ’ No, what I reaIIy wanted to know 

s mean, did you go often? 6 iswfratkindsofideasthatyourecallhearingabouthowbtlp 

1 THEwlTNm: I.nthebe&mingtlEywcn2setup 7 could come to tfie Hubbells. 

% withjustasmallgroupofus. We’dgettoge&ronTuesday 8 THE WlTNESS: People didn’t talk about it in those 

3 nights. And we jokingly used to call it our “Arkansas 9 tams It was more of - well. let me back up. People would 

1 night.“ 10 always say, “What can I do?” And if I was ever asked that, 1 

I Itgrew,becausewereallyhadfun,anditwasone II al~ysrefexmdtbemtothetmstfundthatwassctupfor 

2 of the few times that we ever actually so&I&d or left at 12 the Hubbell children, and that was my standard reply. 

I atimethatwasreasonable. WewereaIlworkingverylong 13 1 think a lot of times it was a rhetorical question 

I hoursthen. 14 of, ‘I don’t know what to do. And this is a bad situation.” 

i Others wanted to come, and it got bigger, and we I 5 But I don’t have any memory of orchestrated - like if a 

; would have these - what it started out as, 1 think, six 16 groupofus~togethaandsolsaid,“Well,weneedtodo 

1 people grew sometimes ta 12 and 15. I stopped going when it 17 x, y, and z for Web.” That was never the kind of 

I got really big like that. 18 conversation that I heard. 

I THE FOREPERSON: After Web Hubbell started having 19 MR. WISENBERG: Why did you focus on the 

) these problems, and he left the Department of Justice, did 20 recommending the trust fund for the children? 

tht Arkansas dinners continue? 21 THE WTMESS: lk!cause 1 knew that was a kgd up 

1 THE wrr~~ss: I think that they had stopped by 22 front entity. It was the only thing 1 knew that people could 

- 

I then. I -- 1 don’t think - no, because his - I’m trying to 23 do. 

I mba when all tk wives candy, when Mrs. Fos~~ and Web’s 24 h4R. EMMICK: Yes? 

; wife Susie. They all came up, I think, in June of that first 25 A JUROR: You testified that you instructed the 

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1 Secret Service -- when you were at this reunion with the 

2 President and Dolly Kyle Browning, that you instructed the 

3 Secret Service not to let Dolly Kyle Browning be alone with 

4 the President? 

5 THE WlTNESS: Not leave the room. 

6 A JUROR: Oh, leave the room. 

7 THE WlTNESS: Leave the room. 

8 A JUROR: Was that instruction motivated out of a 

9 concern that Sk mi@t claim something happened ti uxm 

o that might or might not really happen? I mean, what were 

1 you -- 

2 THE WITNESS: I found her to be extremely peculiar3 acting. And there are a lot of nuts, nutty people, and we’ve 

4 had a lot of situations at the White House of people trying 

5 tobreakinandpeople-weget-youknow,Iusedtobein 

6 charge of correspondence, and I used to have to read all the 

7 hatemailthatcameinandallthcmailthatwetumcdover 

8 to the secret service. 

9 Dolly alarmed me, and I thought she was gaming him 

0 in the way that men and women can game each other around, 

I that there! was sort of a tension there and you could - on 

2 her part It’s almost the flip side of flirting with 

3 someone. It’s -- it’s a taunting in a way, but it was - it 

4 had a sexual overtone kcausc sk was a woman and tk way sk 

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A JUROR: So was your concern for the h?SihtS ’

physical safety or for some kind of unpleasant incident? 

-t-I-E WITNEss: I didnt ’think the President needed 

to be around Dolly Kyle in any kind of way that anyone coulc 

talk about it, yeah 

A JUROR: So it was a perception. 

THEWENEX% Theperception,yes. Just that - 

and my antenna went up. I just had a bad gut on her. 

MI2 EMMICK: Theres ’ a questiOn? 

AJUROR: whathasbeenyOUrjKdOn-CKCCUhjOU ’

tell me what’s in your position that gives you this kind of 

function to tk sort of a guardian to the President? 

THE WITNJZSS: It was just for that event, and it 

wasbecauseeverytimethePmsidentgoesanywbae,somenne 

accompanies him to act, as I explained earlier, like as a 

body person, you know, that carries the papers, give him 

somethmgtodri&justarethereincasesomeonetbathc 

meetshasaquestion,thatheturnsaroundandrefasthatto 

me. 

I’ve done that at various functions, both in the 

White House and on the road 

This was a group of people that I knew well. You 

know, I’m from there, I knew most of the people in that room. 

And so it was - 

A JUROR: You say that another part of your 

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position was, you dealt with the hate mail that came in to 

the President 

THE WITNESS: That was -- no. That’s the very 

fust job that I had at the White House when I was director 

of correspondence We got all the mail in there, and before 

I sent anything or allowed anything to be sent over to the 

Secret Service to have it checked out, I would read it to 

make sure it fell under that definition. 

Because the Secret Service takes that stuff very 

seriously, and it’s -- they take action on it. 

A JUROR: Oh, thank you. 

A JUROR: I have a quick question. Correct me if 

I’m wrong, but I hind of remember hearing that whenever the 

President travels, either the chief of staff or one of his 

deputies~tnivels with the President on every trip that they 

go on. 

Was there a deputy chief of staff or the chief of 

staff on this trip? 

THE WRNEZ~: No. And that is usually the case. 

That became much more institutionalized under Mr. Bowles. 

Mr.McLanycIidn’tadberetothatintbesameway. And 

particularly because Mr. Lindsey generally travels with the 

President everywhere, he always fuactioncd -- or hc didn’t 

always function that way. He was just a senior person there. 

And up until, I think, Mr. Bowles’ tenure, and even 

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not in the beginning of tha< that became more 

institutionalized, that there is a chief of staff person, and 

Page 12, 

now I think that’s fair to say that every time he travels. 

But back then, particularly if he were going on 

something like this, which was of a semipersonal - or al 

IeastthebuIkofitwasapefionaltripbackhometohis 

family, there was&it that necessity, same necessity. 

A JUROR: Thank you. 

MR. Eh4MICK: Sir, if you want to, go right ahead 

BY MR. BARGER: 

Q I just have a couple questions, going back to 

Hubbell. I have a couple topics. 

The trust fund that you alluded to you, what was 

your understanding about the Hubbell children’s trust fund? 

A Justthat Ithoughtitwasafundsetuptopay 

for the schooling for the kids. 

Q Who would you advise people to contact, or who did 

you advise them to contact? 

A Mike Shively. 

Q Did you ever give any fmancial support to the 

Hubbells during tl~ - after his guilty plea? 

A OtherthangivingthemmyhouseforQ Well, other than the housc~yes, I’m sorry. 

A No. I’m sure I bought presents, bought dinners, 

that sort of thing. But, no, I’ve never given a cash 

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Page 129 Prg 13 

1 payment. I worsens every day. So -- 

2 Q How often would you say you talk with Webster 2 Q Well, what has he said to you? Beside wha you 

3 Hubbell now, say, within the last six months? 3 think, what is it that’s led you to think that based on ubt 

4 A It kind of cycles in and out I try to always talk 4 he’s told you? 

5 tohimoncea%zek. I-- 5 A Well, he can’t find a job, other than the job that 

6 Q Do you talk - I’m sorry, go ahead. 6 is very part-time that he has with a small company ovc in 

7 A I feel guilty that I don’t talk to him every day. 7 Virginia. 

8 Q Do you generally call him or does he generally call 8 Q Has he ever -- since he pled guilty, has he 

9 you? 9 complained about the subsequent tax bills that he owcs :o the 

0 A No, I always call him. IO various taxing authorities, such as the IRS? 

1 Q You say ‘how.” Was there a time when it was I1 A He’s not complained about it, but I’m aware thz he 

2 different? 12 owes a tremendous amount of money to the IRS. 

3 A Wbcnhewasinprison,hehadtocallme. 13 Q And how is it you’re aware? 

4 Q And now that he got out of prison, generally you 14 A I’ve read about it. He’s always -- be’s never 

5 callhim. 15 deniedthat6 A Generally. He caUs - Web -- Web doesn’t want to 16 Q Well, has he discussed it with you? 

7 impose on anybody now, and everyone that gets near him gets 17 A Not in detail, no. 

8 caught up in this web. No pun intended. 18 Q When you say, “Not in detail,” what does that nxan? 

9 Q Generally do you call him at his home or at work? 19 A Well, when Web would talk about his situation, and 

10 A Wherever I think hc is. 20 I would be talking about the future and what he could do, it 

!I Q And where is that usually? Where do you usually 21 always comes up that k owes this eancndous amount of mcccy. 

2 think he is? 22 The IRS chunk of it, I’m sure, grows daily. 

!3 A At home or at work. 23 Q And you may have covered some of this, and Mr. 

!4 Q So over the last six months, you would estimate 24 EaunickmaybavccoveredallofitwbcnIwasoutoftkrorm, 

Y you’ve talked to him about once a week. 25 but, in general aside from recommending that people tzn hell 

Page 130 Page 13: 

1 A 1 hope SO. I through the trust fund and contact Michael Shively, you’re 

2 Q I don’t understand What do you mean, you hope so? 2 not away of people suggesting or offering to fiid employmer 

3 AIhO@hZitIdid. 3 for Mr. Hubbell? 

4 Q Is that your estimate of how often you do? 4 ACOrrect 

5 A I hadnt ’ thought about it before. I hope that I 5 MR_ BARGER: That’s d I have. 

6 talktohimonceaweek. Idon’tknowifI-thatIbave 6 MR. EMMICK: Okay. A few more questions here. 

7 donethat 7 BY MR EAIMICK: 

8 Q Okay. what is yourproblemwith that? Maybewe’= 8 Q When you want to get hold of, that is, to tekphon 

9 not commlmicating. MY question is, approximately bow often 9 the President, how do you do it? 

o bave you talked to Mr. Hubbell, on average, over the last six 10 A CalIhim. Justpickupthepboneandcalldz 

I months, not what you hope to do. 11 operator. 

2 A Well, on average, it would probably average out 12 Q You call the operator. 

3 cmceaweek,butIdon’tknowthatIiteraIlyIdiditoncea 13 A Mxn-hmm. 

4 week. 14 Q And if he’s in the residence, what number do you 

5 Q Iunderstand. 15 call? 

6 A How’s that? 16 A IdtheOperatOr. 

7 Q On average, your best estimate is about once a 17 Q Still? If he is out of the white House, how do you 

8week. 18 make the call? 

9 A Right 19 A Call the operator. 

?I Q WhenyoUbaVetalkedtOhb,haVeyOUtalkedtOhh 20 Q Okay. So that’s really the only way that you get 

11 at all about his cumnt financial difficulties? 21 hold of him. He hasn’t got a private line, an insi& line 

!2 Let me rephrase the question. Has he talked with 22 that you could use to call him--y? 

13 you or disclosed to you whether he has any current financial 23 A He has, I think, a private line, but I’ve never 

!4 difficulties? 24 used that private line. 

!_C A I think his financial situation has worsened and 25 Q So you don’t have the number for that ptivare line 

- 

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Page 132 

Q Same questions uith respect to Hillary Clinton. 

A I don’t know that she has a private line, and I’ve 

never called her anyway, except through the operator. 

Q Do you know that there is a way to call her excepl 

through the operator? 

A No, I didn’t mean in private. I do know that_ No, 

I don’t think there is. 

Q Have you had occasion to talk to the President’s 

attorney, Mr. Bennett? 

A No. 

Q What about t0 anyone on his staff? 

A I don’t know who’s on his st%ff, but I don’t - to 

my knowledge, no one has ever identified themselves as 

working for Mr. Bennett that I’ve ever talked to. 

Q What about Mr. Kendall, the other attorney? 

A Iknowhimpersonally,andIhavewan~totalkto 

him when all the stuff first broke about Monica, whenever 

that was. 

Ml&i-Pi3gCW 3-26-98 

, 

I Page 135 

1 BY MR. WISENBERG: 

2 Q So there does appear to be some kind of 

3 infomtion-sharing agmnmt, howwa informal betwam your 

4 laqrr and Mr. Kendall. 

t 5 A I certainly authorized that. 

6 ?&L EMMICK: I wanted to -- unless you had more 

7 questions on that score? 

8 !.QL WISENBERG: Not on that particular topic. 

9 BY MR. EhJMICK: 

1 0 Q Is there a joint defense wt? 

1 ,l A I don’t think so. I mean, I don’t know -- I don’t 

1 .2 know of that. That term’s never been asked of me or brought 

1 3 up by my lawyer with me. 

1 4 Q Okay. 

1 5 BY MR. WISENBERG: 

1 6 Q Do you know whether this information-sharing, 

1 7 whatever you call it - whatever one would call it, I’ve 

1 8 described it as information-sharing -- do you know whetha 01 

1 9 not it’s been formalized in writing? 

2 10 A Not to my knowledge it hasn’t. 

2 !I Q If it has, you haven’t signed it. 

‘2 :2 A &rrect 

2 :3 BY MR. EMMKK: 

2 4 Q Circling back to what we described a couple hours 

2 5 agoasthetimeline,orIdescribeditthatway,Iwautedto 

Page li. 

Q WhenyousayyouwantedtotaIktohim-- 

A Well, I wanted to tell him that I had spoken to 

Monica, and ihat she had in&viewed, and I didn’t know 

whether he knew that, bozausc I didn’t think anyone other 

:4 than Monica and I, just a few people knew that we’ve had 

:5 those exchanges. 

Page I34 

1 Q So you said you wanted to talk to him. Did you 

2 talktohim? 

3 A I did not. We never could get together. 

4 Q Didyoutalktoanyoneelseonhisstaff? 

5 A No. 

6 Q D0y0upfanontalkingtoeitbaMr_KendallorMr. 

7 Bennett shortly after this? 

8 A I don’t_ 

9 Q Do you know whether there are any such plans? 

0 A Formetotalktothem? TherearenOt. 

1 Q Okay. 

2 BY MR. WISENBERG: 

3 Q How about the New York Times, is it part of the 

4 information-sharing understanding? 

5 A I don’t think so, but I told my attorney that he 

6 should share any information that 1 have with anybody that he 

7 thinks is relevant, too. 

8 BY MR. EMMICK: 

9 Q Has he told you whether he’s shared any information 

o with Bennett or Kendall? 

1 A I don’t think he’s ever talked to Mr. Bennett. I 

2 think he’s talked to Mr. Kendall, because I think that Mr. 

3 Kendall suggested that instead of Mr. Kendall talking to me, 

4 that I ought to talk to my lawyer, and then my lawyer could 

5 talk to Mr. Kendall. 

___. -. ___ 

1 show you a couple things and see if I -- 

2 A Wait. I’ve got to get my glasses. 

3 Q Okay. 

A Excuseme. 

Q What I’ll do is, I’ll actualIy show you one thing 

andthznreadyouafewotberthings. 

A Okay. * 

MR wIsENBERG: Let me just say we’re going to try 

to finish up by 2:30. 

1 h4R.EMMICK: Right. 

1 m VfISfZNElERG: If we don’t, we might have to have 

1 you back. It would not be very long, I don’t think, but we 

1 might have to do that_ 

1’ THE FITNESS: Okay. I’ll be really fast, very 

1. succinct here. 

11 BY MR. EMMtCKz 

1’ Q I’ll read fast_ What I hold in my hand is a copy 

11 of what appears to be a letter or a draft of a letter. It’sl! not signed. It’s dated July 6, 1997, to Ms. Marsha Scott 

21 ‘l%enameatthebottomis”MonicaLewi&y”anda&thebp, 

2 “Monica Lcwinsky,” with an address. It has soax hi&lighting 

2: on it, but that’s of no significance for this. 

2: 

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I’d like this to show you this to you and ask you 

if that appears to be one of the letters that Monica scat to I 

you. I 

Page 133 - Page136 
3607 

Q who’s “he”? 

A well, 1 guess there’s a couple ways of answering 

that, but we’ll have to leave it to inference who “he” might 

be. 

What portions of that square with your 

recollection, or might help you remember what happened in 

that meeting June 16th? 

A The part that doesn’t square is the “he” reference. 

I don’t understand her characterization of assumption of wha 

I know or don’t know. 

And if you want me to go further, we have to go 

back over it piece by piece. 

Q I take it, you don’t take issue with., “While she 

was very pleasant” 

A -No, I like that part. 

Q AU right. “She questioned me endbsly about rnJ 

sihration.” 

n x-c: Grand Jury Proceedings MU&i-PagP 

Page 13: I 

1 A (Examining). This -- this could be one of the 1 

z letters she sent to me, but I can’t attest to it_ 2 

3 Q Have you had a chance to read all the way througl 1 3 

4 it? 4 

5 A Yes. 5 

6 Q What is it about this that reminds you of the 6 

7 letter and makes you think that it could be one of the 7 

8 letters? 8 

9 A Just the last paragraph 9 

.O Q Last paragraph -- 1 0 

,1 A Yes. 1 1 

,2 Q - saying -1etmejustreaditfortherecordso 1 2 

i3 weknowwbatitsays- “Marsha: IwantyoutoknowtbatI 1 3 

.4 do appreciate the help you’re giving me, and I apologize if 1 4 

s at times my fiushation with this whole situation has been 1 5 

:6 misdirect4 toward you.” 1 6 

.7 Now, this is dated July 6th, which would have 1 7 

8 placed it after the first meeting which we were tentatively 1 8 

9 placing at June l&h, but sometime before the possible second 1 9 

!O meeting on July 16th. 21 0 

!I So this would have been, I guess by any accounts, 2 1 

!2 before the meeting where she was crying. Does that sound 2. 2 

!3 right to you? 2 3 

:4 A we~,~I~~x remember it, I’m not sure how 2, 4 

!S much happened in the fmt m&ing versus how much happemd 2. S 

Page 138 

1 in the second meeting. I’ve aever, ever wanted to give the 

2 impnzssiantbatI~berwbathap@atwllicllmeeting. 

3 ~I~~~g~~~ndo~,butI4 IhopeI’vebeenclearthatI’mwtpositiveaboutthat And 

5 she could have e&d both times, for all I know. 

6 Q Allright. TheaextthingIwanttodoisnzadyou I Q 

7 a - this is a letter dated June 24,1997. So, again, this A 

8 would bc approximately eight days after t&at fust meting, 1 Q 

9 tentativefirstmee~orwbatwe’reassumingisthefust t A 

0 meeting. l( 

1 And I’II read a passage relating to your meeting 1. go. 

2 with Monica. Tell me wbetk this helps you remember- 1; 

3 may have happened at that first meeting. 1: 

4 “My meeting with Marsha was not at all what I Id 

5 expected. While she was verypleasanf she questioned me 1: 

6 endlessly about my situation. Despite the fact that Sk 14 

7 alreadykaewwhyIhadtolmve,sheaskedm:totellbs~ 1’ 

8 about it, asked if I bad acted ‘~p~p~~ly,’ and why I 11 

9 wanted to come back. She seemingly knew nothing about my l! 

0 current position. 2( 

1 “She didn’t know of any openings and said she would 21 

2 check with the people in communications. He said to me that 2; 

3 be had told bcr I’d gotten a bum deal, I should get a good 2: 

4 job in the West Wing. I was surprised she would question his 2r 

5. judgment and not just do what he asked of her.” 2! L 

A That -- we& that’s her interpretation that -- we 

discussed her situation, as I indicated earlier. 

Q “She already knew why I had to leave.” Somehow the 

author of this letter seems to have come to the conclusion 

that you knew why she had to leave, 

A She may have assumed that. 

Q All right_ But your recollection is, you did not 

know. 

A We& here again, as I’ve stated earlier, my 

recollection is very imprecise about how much Betty Cunie 

badactuaitytoldmc*boutMonicaandwbenIachlaltylcanvd 

the pieces about Monica having to leave and why, 

theolztieally, she had to leave. 

other document. 

THE M)REPERSON: Oh. Well, while you’re looking 

for it, just a quick question. 

MREMMICK: Yes. 

THE FoREPERsON: What_ agaiq were the approximate 

dates of the reunion? Do you recall or is it? 

THEi WITNESS: It was hot, it was summer. 

THE5 FOREkRsON: It was hot. 

THE WTTNESS: t’m guassing it was probably July or 

August because -- 

THE FOREPERSON: Was&at ‘97 or -- 

THE WlTNESS: I think it was - it would have been 

‘95, wasn’t it? I don’t -- 

3-26-98 

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AIlright WhatIwanttodoDoyouwTmtmetoreadanythingelse? 

No. ‘ 

okay. 

THE F0REPERSON: Just one last question before you 

MR. EMMJCK: Actually, I’m going to ask about OIIC 

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THEFOREPERSON: Okay,okay. 

BYMR.EMMICK: 

Q What I’m finally going to do is read to you another 

-- let’s call it a document. and this one is dated September 

17th. Keep in mind that what I was postulating to you was 

some sort of a mezting June 16th; a planned meeting, 

probably, on July 16th -- it’s unclear whether that was 

actually a meeting or not; a possible meeting in August; some 

communications with Liz Bailey later in August, perhaps as 

late as the 25th. 

Here is a document that is dated September 17th, 

and here’s what it says. “Yesterday morning I went to I 

farewell ceremony for someone hereandsawtheW%iteHous 

liaison wman with whom I met last mdc about being detaikd. 

I asked her if she got my tmail and she said she had and 

asked if I had spoken to Marsha recently. I said, “No, whfl 

She said Marsha had run into a few snags and I should talk tc 

her. 

“So I called Marsha all day long yesterday and 

finally got in touch with her about 5:00 p.m. She has been 

stripped of the detailee slot in her office, so for now there 

isn’t anyplace for me to be detailed, so I should be patient. 

“I told her I was very upset and disappointed, em 

though I really” - it’s unclear here. “Then she and I goi 

into it. She didn’t understand why I wanted to come back 

when there were still people there who would give me a hard 

time and that isn’t the right political climate for me to 

come back.” 

Andthenitgoescm. 

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D description, though, consistent with the last of the 

1 conversations that you said you had with Monica? 

2 A YeS. 

3 Q All right. 

4 MR. WISENBERG: we'= going t0 have t0 Stop. 1 

5 don’t think we’re quite finished. We appreciate your 

ThefactthatthisisdatedSeptember17th,does 

that help you place in time when you might have had 

discu&onswithMonicaLewinskyabfiuta&ailnotbeing 

available and having “gotten into it” with Monica Lcwinsky. 

A No. The gist of it fits with what I remember 

telling her. Where I’m off - and I am very imprecise about 

timeanddates- in my mind, it was a much shorta expanse 

of time that I spent dealing with Monica Lewinsky. 

This strings it out much longer in time than I 

remember. Idon’t- it could have easily been betwlcen June 

and September. In my mind it wasn’t, but it could have 

MR. WISFCNBERG: were ’ go& t0 ht! ’ to stop WW. 

MR. EMMICK: Hold on one see here. 

BYMR.Eh%U.lCK: 

Q My question then is going to be, is this 

Page 142 

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patience. 

Page : 13 

I just had a conversation with your attorney. ; 

understand you’re going to France next week on Ihur+ ‘

you’re going to be back in town Tuesday. Before. you 1~;s -- 

THE WITNESS: Oh, yes, 1’11 be here next Tuestiy. 

MR. WISENBERG: Okay. We’ll set up a tentat-;: 

time with your attorney to be back on I:30 for pek;.s 

another hour of questioning. 

THE WITNESS: Okay. 

MR WISENBERG: So, with that, we apologize that ur 

didn’t finish. Thank you for your patience. And I’ll a& 

may the witness be excused? 

THEFOREPERSON: Yes,shemay. 

(The witness was excused.) 

(Whereupon, at 2:32 p.m., the taking of the 

testimony in the prespncz of a fuII quorum of the Grand ky 

was concluded.) 

***** 

Page 141 - Pa_c:Y43 
3609 

page2 

PROCEEDINGS 

Whereupon, 

A4ARsHAscoTr 

wascaIlaiasawitncssand,aftcrhavingbeendulyswomby 

thcFoxpasonoftbcGmndJury,wBsexamhedandttstifiad 

as follows: 

EYMhfINATION 

BYtvfREMhKk 

Q Would you state your name and spell it for the 

record? 

A Marsha S&t, M-a-r-s-h-a S-c-o-t-t. 

Q Welcome back. 

A Thankyou. 

Q Letmenxnindyouofsomeoftherightsand 

obligations that yoti have, as we have on other ouxsions 

Number one, you have the right to consuIt with your 

attorney. You have an attorney here with you? 

A Yes. 

Q And if you need to consult with your attomey, jusi 

tell us and we’ll let you step outside and do that 

consultation. 

In addition, you have the right to invoke the Fii 

Amendmwt That&ifyouhcaraqutstiontheanswato 

which would cause you to incriminatt yourself, you have tk 

righttosay’Ircfuseto wswaonthcgmundsoftheFtith 

hxrxhent.” Do you understand that? 

A YeS. 

Q You also have an obligation, the obligation ; 

tell the truth, and that obligation is imposed upon 

bemuse you have taken an oath. Do you understand th 

A Yes. 

Q And if you were to intentionally state a I& 

would expose you to prosecution for perjury and pe;?u, 

felony prosecutable with a five-year maximm snlc3a 

you understand that? 

A Yes. 

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24 A Okay. 

2.5 ’ Q I believe it was- Does that ring a 1 

Q All right. Do you have any questions bd~n me 

fiuther? 

A No. 

Q Allright. Letmeaskyoufirstwhherornc 

sincetbelasttimewemetyouhavehadocxasioototi 

about your testimony and have recalled anything n 

anything different from any of the subject, that we 

discussed in tk past. 

A No, but you had asked me about two diffaent ite 

Onewasapboocnumbu. Doyoumindtcllingmctknumbc 

again? 

Q Yes. Or, no, I don’t mind. 

Multi-Pagem March 31, 

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A It doesn’t. 429, though, is a line htrc in 

Wash&ton. I mean, that’s a normal m number. U% 

the time on that? 

Q ‘IhenwcrcanumbcrofcaUs,whicbwastknrrm 

for our intexst, and they ranged throughout the da) 

AWhatyear? 

Q AIMthin tk 1~ two months. 

A l%at’swh8t’soddbcsausethat’saImaat~n~ 

thatwasthcgaxralnumkrwhcnW~bHubbdIbedtbe~i 

in Michael Cordoza’s building, but that was three m 

Q No,thiswouldhavebeentklasttwomontlx 

A Andthatnumberwas’-‘mean& 

3 close, it’s odd. E3ecause I called - I looked througl 

4 Rolodex, I couldn’t find it, but I found that numba 4 

s called it and that’s still the nxeptionist’s number 81 

6 G. William Miller. 

7 Q Allright, Ithinkwcmentionedtoyou-thatB A That’s all the sleuthing I did on it. 

9 Q ~thinkImentionedtoyouthatwhemwea&e 

3 phone company about the location of that number tl 

I indicated it was in the State Department and that di 

2 strike any bells for you? 

3 A No. I tried cahcthat number, got noth& 

Q so I called tk other number that I did have and I gc 

s G. William number. 
3610 

MUki-PagC2N March 31, 1998 f 

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Q All right. Well, that’s probably the best we can 

do. The other thing that you were going to look into? 

A ‘be dates of when I was out of the country and that 

was July 16th through July 3 1 st. 

Q Now, when you said July 16th, it strikes me that 

that was the day of the WAVES entry and so it makes me ask 

when on the 16th. Do you remember at all? Because that 

might help tell us whether you were unavailable at that time 

for that WAVES entry. 

A All the flights leave at night and they all leave 

at -- I think it’s at 7:20, so I can’t find any record or 

anything tbat @@us my mcmoty of wk&r I actually worked 

most of the day. I tried calling friends that I had traveled 

with, I’m sorry, I just don‘t have - I could have been 

there. 

Q All right Fair enough. That’s probably all we 

can do for now, then. All right Good. 

I wanted to ask you a number of questions, some in 

different areas, some in the same areas, and let’s just start 

with the following. 

Did you ever have any discussions with anyone about 

trying to get or possibly getting Monica Lewinsky a job on 

the 1996 presidential campaign? 

A No. 

Q Have you ever heard of anyone trying to get her a 

Page6 

job, a position with the campaign? 

A I haven’t, 

Q Would she have been suitable, in your view, for a 

position of that kind? 

A It would have depended on what she wanted to do. 

Q All right_ Let me ask you some questions about a 

different person, Kathleen W&y. Do you know E&&&z5 

Willey? 

A I’ve met her. 

Q When did you meet her? 

A Oh, some years ago. I don’t remember the first 

timeImether,butshefiadanoccasiontotalktomeona 

couple of different times about help in finding something in 

the White House. 

Q Do you remen&& about when that was and I suppose 

we could try to bracket it timewise, but let’s just start 

with your best recollection of when those discussions were. 

A I don’t know when and if she actually worked thae, 

but it was prior to her having a job, so -- 

Q After she was volunteering, but before she had a 

job? 

A &-r%t. 

Q Or was it before she was even VOhnttXXing? 

A No, I think she was volunteering because she was in 

the building. 

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Q And what caused you to want to speak with her about 

getting a job? 

A I was called by someone and this would have be 

when I was -- let me think what I would have been doing tbzo. 

I could have still been Director of Correspondence or maybe I 

was in the Public Liaison Office because I think she was way 

back in time Someone call4 me and askal me if I would talk 

to her. My memory is txxause they I&d her and they felt 

sorry for her. 1 mean, she needed some help. 

Q What’s your best recollection of who would have 

been making a call like that to you? 

A I tried to remember that and I -- this will sound 

funny, but my connection, and it was someone in the building 

it was SOUSQM in the White House, but my connection was that 

hex co-t&m was with the Democratic Party. 

My~~of~~~d~tI~a~t~~ 

that she and her husband wexx long-time friends, Democrats, 

and that it was someone who was connectediIlsOmeWayWiti 

the Democratic Party that knew her and was asking as a favor 

if I could help her brainstorm and think of anything that 

there might be for her to do. 

Q You used a phrase “long-time friends.” what does 

that mean? 

A I took it that they were supporters, Democrats. 

Q Isee. 

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5 Q And you’re friends with Haroiyn. 

Page 5 - PT&e 8 

Page ti 

A Imean,Ilrnewofherinthecontextofherf~y 

were Democrats. 

Q Youwerecalledbysomcone. Hady0uevenbeard0f 

Kathleen Willey before this call? 

A Id~‘t~~,but-~~~~~~~ 

youguysbocausethcnyougoandmcssotbcrpcopb’slivcsup 

by sub& t&n and they have legal bills, but I’m good 

friends with Harolyn and Michael Cordoza. I know thal 

Hat-o@ is a long-time friend of KaNeen’s or knows her 

well. Harolyn is a very nice person. She at one time 

volunteered in the social office. 

Harolyn could have asked me, but I could be making 

this up, too. That is truly a wil& off-t&cha&gue~. 

I have no clear memory that Harolyn did, but she could have. 

Q But you hadn’t heard of Kathleen W&y before, 

tbenyouget thiscau, txmxxmesayssoerethinglikeKathieul 

W&y’s a nice person - 

A No, I’m sorry. What I meant by bringing Harolyn 

Cordoza into this is Harolyn could have told me about her 

friad Kathleen voluuteering in the White House. I could 

have knoti about her around that_ 

Q Isee. 

A Because I now know that HGolyn is friends with her 

and I could have known that then. 
3611 

PazeN March 31. 1998 

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A And I’m friends with Harolyn. Yes. 

Q b’s follow up on the assistance to Kathleen 

Willey part of this. SO you may or may not have know 

Kathleen Willey. you get a call from someone in the White 

House saying can you help out Kathleen Willey. 

Any idea why the call would have gone to you? 

Are you the logical person to have called? Because at 

that time, you’re Director of Correspondence or possibl 

the public liaison. Why would it be you whom they would 

call? 

A I’m a nice person. I’ll talk to aImost anybody. 

And I also - I try to solve the problem and I don’t 

mind taking on things that aren’t directIy any of my 

business. 

Q Okay. You get the call and what happens after 

that? Do you call Kathleen WiIley? Does she call you? 

What happens? 

A Ijust remember meeting her briefly. I actually 

remernbermorebowsbelooksratberthanwbatshesaid. I 

didn’t - you know, I wasn’t in the business of getting jobs, 

so I didn’t know what to suggest to her. 

Q What did you mean by you remcmbcr more how she 

looks? 

A I mean, just my impression is I just remember her 

physically. I thought she was attractive, she bad long brown 

Page It 

hair and she was very nice. I thought she was an extremely 

nicepersonandseemedveryeagertogetajobandIthinkI 

nememberberalludingtotbefactthatshereallyneededa 

job. 

Q Did she indicate why she needed a job or did you 

have some impression or understanding why slmz needed a job 

A Idon’tthinkwegotintoany-indepthon 

anything_ My general impression was just that she really, 

reallywantedtoworkandforsomreasonIthinkshewassbe may lizwe been volunteering in the counsel’s of-lice then. 

Q Okay. Did she indicate whether she had been 

contacting anyone else witbin the white House to try to find 

anotkr job? 

A WeI.kIthinkthat’showIknewabouther. Ithink 

it was from others who were trying to help her. 

Q So basic.aIIy Iike an expansion of the network of 

people trying to find a job for Kathleen Willey? 

ACorrect. 

Q Long meeting? Short meeting? 

A I don’t remember it being long at all. 

Q DCI you have an impression of whether it was before 

or after the suicide of her husband? 

A I don’t have an impression. I would not have 

remembered it at all, except I saw an old picture of her and 

that triggered that I remcinbcmd having seen her. It wasn’t 

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Page 11 

anything that sticks out, other than that. 

Q How were things left at the conclusion of that 

meeting? 

A I don’t know that they were. I don’t know that I 

had anything -- I’m sure we just brainstormed about different 

kinds of things she might could do. Whether I said I would 

talk to anybody as a friend, you know, I knew all the people 

in the counsel’s office, I certainly wouldn’t have minded 

doing that, but I don’t have a memory of doing that. I don‘t 

even know if that’s what I was supposed to do. 

Q Do you remember if she called you to set up the 

meeting or if you called her? 

A I don’t rcmcmbcr. 

Q Would you have remembered it if it were someone, 

somescnior, high-up White House official who had placed the 

eaII? If it was the Chief of Staff or the President, would 

you have remembered that? 

A I think I would have remembered it if it had been 

the President or the Vice Prcsidcnt, but other than that, I 

don’t think it would have made much difference. 

Q You have this meeting with her, not clear how 

things got resolved at the end, what happens next with 

respect to Kathleen Willey? 

A I forget about her. 

Q Did you have any other meetings with her? 

A I don’t think so. 

Page 12 

Q Ail right_ Any other discussions about Kathleen 

WiIIey - Icts ’ just limit it to - let’s say up until the 

end of 1996. 

A No. The only other occasion that Kathleen WiIIey 

blrmpadintomylifewasoncwodwndwknIwasgoiagdown 

with m ftiea& and Harolyo Cordoza to stay at her father’s 

place in Easton. ‘And I remember Harolyn calling me and 

tellingmethere’sthiswomandownthereand~can’tgetber 

out and we were laughing about it and she said that Marcia, 

the housekeeper, kept calI& and saying this woman’s still 

here and the woman in question was Kathleen Willey. 

Q Do You remember when that was? 

A we& maybe in the summer of either ‘94 or ‘95. 

That’sawiderange. I’mtryingto-itwasatscnnepoint ’ 

after Mr. Foster died and I believe he died in ‘94 or ‘93? 

Q Ithoughtitwas’93. 

A ‘93. It was probably the following year. 

Q Probably the summer of ‘94? I guess I’m a little 

unclear - did you actually see Kathleen Willey? 

A Nd. I mean, I just said that’s the only other time 

that - _- 

Q Her name has even come up? 

A Yes. Youasked me -- isn’t that what you asked me? 

Q I don’t think it is, but -- 

Page 9 - Page 12 
3612 

hlult1 

Page 13 

1 A I thought you had asked me -- 

2 Q-- information is information, so that’s fine. 

3 A I thought you asked me u-hen I had had conversations 

4 about Kathleen Willey. Is that what you asked me? Excuse 

5 me? 

6 Q It really doesn’t matter m%at it’s in response to. 

7 A Okay. 

8 Q I’m just trying to get information. And that was a 

9 conversation with Harolyn or is it a conversation with 

0 someme else? 

1 A It could have been relayed to me, but it was a 

2 conversation that was either from Harolyn to me or fron r 

3 Harolyn to one of the people I was going down there with. 

4 Q And the residence, that MJS Mr. Landow’s residence. 

5 A YCS. 

6 Q And you were going there for what reason? 

7 A Harolyn Cordoza had invited a group of women down 

8 and we were going to have kind of Iike a girls’ night down 

9tixl-C. 

10 Q And by the time you got there+ was Kathleen Willey 

!I gone? 

!2 A Yes. I mean, this has nothing to do with anything. 

!3 it’s just -- 

!4 Q You never know. Never know. And anything else 

!S about any job efforts by you for Kathleen Willey? 

Page 14 

1 A Not that I know of or remcmbcr. 

2 Q I’mtryingtothinktomyselfwhetherornotthe 

3 position you now hold is one that would have had any role in 

4 placing her with any subsequent jobs. For example, if I 

5 razall,sbein1994wasonaworldsurnmitgroupthatwentto 

6 CopenhagenwiththeStateDepartment. kthatsomethingtha t 

7 you know anything about? 

8 A No. 

9 Q Your current position, is that a position that 

10 would have helped select her for that position? 

:1 A Yes, that’s what I do now. 

12 Q I see. Same question with respect to a position 

:3 she held at a world summit on biodiversity that was held in 

4 Jakarta. Do you know any-thing about that yourself? 

.5 A No. 

.6 Q Heard anything about it yourself? 

.7 A No. 

.a Q Again, is that the kind of a placemen t that would 

.9 be done by your office now? 

!O A I’d have to look because it depends. Our office 

!I does presidential missions. If that was a State Department 

!2 mission or commcrct Dqartmcnt mission, tlq would do them 

!3 independently of our process. So I don’t know. 

!4 Q So not neczssarily, but possibly. 

!5 A COrECt. 

-Pagem March 31,1998 

, 

Page 15 

1 Q In 1996, .shz was placed on the board of governors 

2 of the USO. Is that sornething that your office would have 

3 played a role in? 

4 A Not something I would have played a role in, but 

5 personnel would have selected the people for that. 

6 Q DO you recall her name coming up as possibly going 

7 to the board of governors at all? 

8 A No, but I don’t think I was there then. I could 

9 have been. 

0 Q 1996? 

,I A I was there ‘97 to ‘98. 

2 Q ‘97. All right_ And you have no independent 

3 recollection of her seeking that job or getting that job at 

4 all? 

5 A &rtXt. 

6 Q And let me turn to a different time period, but 

7 also with regard to Kathleen W&y. In July and August, 

8 some newspaper or magazine articles came out - 

9 A What year? 

!O Q I’m sony. Of 1997. 

!I A Okay. 

!2 Q Some articles came out discussing Kathleen Wiuey 

!3 andwhethershe’dhadsomesortofanencounterwiththe 

!4 President back in ‘93. Let me ask you whether you recall 

!5 that subject coming up in any conversations at the wh: 

Page I\ 

I House. 

2 A Probably. 

3 Q Okay. probably meaning that it probably came ul 

4 but you don’t xecall or - 

5 A It probably came up and I don’t recall any 

6 SpecificS. 1 -that was - you knaW, it wan ShOCkin 

7newsatthetinqsO8 Q Whcntbatcameout,didyourecogn& the Katlllazl 

9 Willey name? 

0 A I did not I didn’t nxogn&hername,I 

1 recognizalherpicturqtben1 lWXIUbCredWiX5lZIhadscCn 

2 her before. 

3 Q Andthiswxx.ldhavebeen,again,inthesummer 

4 of ‘97 that you saw a picture of Kathhxn Wiiey and said, 

5 “Ah,1 remember that person”? 

6 A Atsomepoinftherewasapictureofherwithlon 

7 hairand remember wIm the story fvst broke, I didn’t have 

8 aclucwhothat womanwas. Andrhcnatsomepoiar,tlmewas 

9 a picture published of her that showed long hair and that’s 

!O when1 mnemtmedtbat’sthewomanthatIhadaumnectioo 

!I with. 

!2 Q And so I’m clear, when yu’re talking about wh 

!3 the story broke, you’re talking about this period in late 

!4 July when a Drudge Report version of the story came out and 

!5 then early to mid August when the Newsweek article by Mike 

Page 13 - Pa@ 16 

_. ._.._ c 
3613 

Mult Pagem 

Page 17 

1 I.&off came out? 

2 A Correct. I assume it would have been in there. 

3 Q That’s consistent with your recollection about when 

4 it was? 

5 A Yes. 

6 Q All right. All right. Do you know anything about 

7 any efforts to place Kathleen Willey with the Democratic 

8 National Committee, the DNC? 

9 A No. 

0 Q Let me ask a few more questions. Do you have any 

1 recollection of disaxsions with persons in the white House 

2 about the Kathleul Wiiey alIegation& whether they might be 

3 true, whether they’re outrageous or no< whether they’re 

4 false, anything like that? 

5 A No. 

6 Q It ties me as unusual that you wouldn’t recall 

7 thatorthat8 A Well, like I said, when I hear& that was shocking, 

9 .soyouaskmeifpeopleweretalkingaboutit,I’msuretbey 

10 were. I don’t remember any specific conversations. We get a 

:I scandal a day, it seems like, so it’s -- I don’t know - I 

12 don’t know how to react other than not to react. 

13 Q Well, then, let me just ask some questions that I 

14 have to ask. Did you ever talk to the President about it? 

15 A I don’t think so. No. 

Page 18 

1 on these kinds of allegations, we’re seeing a lot of people 

2 using people to try to get at him in this way. I don’t 

3 believe it. I don’t believe what I’ve read that Kathleen 

4 Willey has said. Of course, I don’t know which Kathleen 

5 Willey I txlieve. 

6 Q This is why you didn’t watch it or talk about it? 

7 A So I choose not to listen to the trash. I don’t 

8 read -- I read very little, only unless it’s forced on me in 

9 some way that involves me, 1 tend to read it. 

IO Q Okay. 

>l A -I-hat’s why. 

I2 Q All right_ Fair enough Let me ask you some 

13 questions that relate back to Monica Lewinsky rather than 

14 Kathleen Willey. First, where did Susan Brophy work 

15 duringthetimcwhaMonicaLminskywastbrreattbeWhite 

16 HOUX? 

,7 A I believe she held the same job the whole time she 

,8 WasthereandIthinkthatthatwastheDeputyDirectorof 

,Y Leg. Affairs. 

!O Q Did you ever talk to Susan Brophy about Monica 

!1 Lewinsky? 

!2 A I didnot. 

!3 Q Do you have any recollections at all about Susan 

!4 Brophy saying that Monica Lewinsky was a stalker, whether 

!5 overheard or in the course of conversations you had witt 

1 Q You don’t sound certain. 

2 A I’m not certain about anything. Too much has been 

3 written and said about all of this. I don’t have specific 

4 memories of any cc~~versation that I’ve had with the Rtzsidetrt 

5 about KatllIeexl willey. 

6 Q No ncolhxtim of specific memories. Do you have 

7 recolleaztions of mare general memories? For example, do yoc 

8 have a general recollection of him denying it to you? 

9 A No, but I wouldn’t ask him about that. 

0 Q Okay. The same question focusing on the more 

1 recent time period. Any discussions, either with the 

2 Resident or others, with regard to the Kathleen Willey 

3 appearance on 60 Minutes just recently? 

4 A No. 

5 Q No specific &collections? No specific 

6 discussions? or no discussions at all? 

7 A I didn’t watch it and wasn’t interested in seeing 

8 it and people that know me know that I’m not interested in 

9 talking about it, so 1 haven’t -- 

0 Q why not? 

1 A Ifinditvexy- it saddens me as a woman that 

.Z we’ve got another woman who I think is putting herself in a 

13 position where I think she’s making up things and serving her 

14 own intexests and it saddens me that we’ve seen women doing 

!5 this. I think because this president has sumed vdnerable 

Page 20 

1 Susan Brophy? 

2 A I’ve never had a conversation with Susan Brophy 

3 about Monica Lewinsky. I’ve never heard her mention her 

4 name. Ibcliev~asItestifiedearlier,mymemoryofthat 

5 is that Monica raised that issue about Susan Brophy and 

6 mentioned Susan Brophy to me. 

7 Q Did you%er tell Betty Currie that Susan Brophy 

8 hadtoldyouthatMonicaLewin&ywasrega&dasa~ 

9 A Ieoddhave. 

0 Q How would that reference come up? If you hadn’l 

1 talked to Susan Brnphy about whether Monica was a stalker, 

2 how would it come about that you would tell Betty Currie tha 

3 Susan Brophy had told you Monica was a stalker? 

4 A Well, that was certainly something - I had told 

5 you when I had got the information that I got about Monica 

6 being ‘The Stalker” and that there seemed to be a.fairly 

7 widespread understanding of that term with her, I feel 

8 confident at some point with Betty I would have gone back 

Y and let her know the direction I was going and why I wasn’t 

o going to go in a direction of getting her a job in the 

1 WhiteHouse. 

2 Q AndIdorecallyoursay&thatyouhadtoldBetty 

3 that part of the problem with placing Monica is this stalker 

4 image, if you will, but I hadn’t recalled that you 

5 specifically said that you’d got some information from Susan 

March 31,1998 

Page 19 

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Brophy on that score. 

Page 2 I 

A I didn’t get any information from Susan Brophy. 

I never talked to Susan Brophy. 

Q Okay. The question three minutes ago that I askec 

you, you possibly misunderstood. I asked you did you tell 

Betty Currie that you had leaned from Susan Brophy that 

Monica was referred to as a stalker and I thought you had 

said yes and that’s what caused me to ask -- 

A No, I said no, I didn’t learn from Susan Brophy. 1 

never talked to her. 

Q Okay. And whether you talked to her about it or 

not, did you tell anything to Betty suggesting you had talked 

to her? 

A No. Because I didn’t talk to her. 

Q Okay. Okay. Any idea where Betty could have 

gotten the idea that you had spoken to Susan Bmphy and told 

Betty that Susan Brophy said that she was a stalker? 

A I think we’re confusing each other. L..et me start 

over. 

Q Okay. 

A I think I HOW what you’re asking. Susan Brophy 

and I never had a conversation about Monica. Monica had a 

conversation with me about Susan. 

Q Okay. 

A I heard about Monica being called a stalker from 

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Page 22 

others and I think I learned it from a group of people that 

may or may not have been Sitting at a staff table with me. 

Q And would that possibly have included Susan Brophy? 

A I seriously doubt it. I just - I don’t have 

interaction - I didn’t have interactions with her. That 

doesn’t fit for me. I would have told Betty u&en talking to 

her after having interviewed or - I shouldn’t use that 

word - after having talked with Mmica that I had heard that 

Monica was called a stalker. 

Since I didn’t get that from Susan Brophy, I don’t 

think I would have told Betty Currie that 1 got that from 

Susan Brophy, since my memory is I got it from Monica about 

Susan Brophy. Anyway, does that answer - 

Q It does except for one little piece. 

A Okay. 

Q Why does Betty think that you mentioned Susan 

Brophy when you had this discussion with her? 

A I don’t know. I don’t know. You’d have to ask 

Betty. 

Q Okay. 

A sorry. 

Q All right. Do you have any reason to think that 

the name Susan Brophy came. up in the conversation you had 

with Betty? 

A No. I don’t. 1 think Betty learned that from 

Pa.gP March 3 1,1998 

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Monica. 

Page 23 

Q AI1 right. I thinkwe've touchedonthis onone 

other occasion, but I want to be clear on it. Have you 

gotten calls from Betty before to help a friend of hers or 

someone that she knows find a job? 

A Probably. And now you’re going to ask me who and I 

don’t bow. 

Q Okay. I’ll ask a few more questions, too. Roughly 

how many times do you think that may have happened? 

A Well, I’ve known Betty, as I said before, five and 

a half years now. I would bet my last dollar that thae have 

been occasions through t&c years where we have &cussed 

different young people in the office. I’m trying to think 

back through who some of the interns were. And I’ll come up 

with so&e names in a minute. 

Q Just so that we can bracket in general how many 

we’re thinking of, you’re having in mind soxnewhex between 

one and five or somewhere between five and ten, more than 

ten? 

A I honestly -- 1 haven’t a clue how to answer that. 

Q Doyouhavetheimpressicmthatsomeofthemwere 

interns or not? 

A Probably. 

Q When you say “probably,” I’m not sure whether that 

means something based cm your recollection or is more just 

Page 2* 

I impression that you have? 

2 A Just an impression. Not based on anything. 

3 Q Have you ever talked to President Clinton about 

4 gettingajobforsomeone? 

5 A Yes. 

6 Q Howoftealf 

7 A 1’11 have to go - we’ve elltenzd into unlalown 

8 territory for me. I’11 have to go fmd out. 

9 MREMMxcK:Allright. 

0 (l-he witness was excused to confer with counsel.) 

1 THE =s: Okay. I’m sorry. 

2 MR. EMMICK: We can’t get started quite yet 

3 MR.WISENBERG: L&the recordreflectthatthe 

4 witness has reentered the grand jury room. 

5 Madam Foreperson, do we have a quorum? 

6 THE FOREPERSON: bfm-hmm. 

7 MR. WISENBERG: Are any unauthorized persons 

8 presentintheroom? 

9 A JUROR: Did you just lock the door? A juror - 

.O MR. WISENBERG: I don’t believe so. 

1 THE AREPERSON: Don’t lock it. 

,2 MR. WENEtERG: No. _ 

3 MR. EMMICK: Because they’re circling around, 

4 trying to get back in. 

5 MR. WISENFJERG: All right. 

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Page 25 Page 27 

THE FOREPERSON: No unauthorized persons. 

You’re still under oath. 

THE -S: Thank YOU. What confused me was you 

asked me if I’d ever had a conversation with the President 

about getting someone a job and I said yes. That’s what I 

do. I mean, that’s my current job now. And I had to ge 

definition about what was appropriate for me to discuss about 

what I do and so I’m perfectly -- 

MR. EMMICK: Okay. 

THE WrrNESS: So now we can discuss whatever. 

I just wasn’t quite sure what I was supposed to do. 

BY MR. Eh4MICK: 

A I don’t have a name that’s coming to mind. 1 don’t 

have a conversation that’s coming to mind. 

Q But do you think it happened? 

A I don’t have a clue. 

Q All right. Okay. Has John Podesta ever asked you 

to try to find a job for someone who then was working at the 

white House? 

A There again, if you have names -- that’s all I do, 

is find jobs for people. I’m right now not - I’m just not 

thinking along those lines. If you have names, I’d be glad 

to go over each name and say yes or no. 

~~ Q So what’s the answer to the question? On what 

occasions? 

A Well, that’s part of my job, so now in the course. 

of what I do, that’s what we’re always talking about, is 

getting people jobs, who has jobs, who doesn’t have jobs, and 

where they are in the process. If you have some specific 

names you want to ask me about, it would probably be easier. 

Q Let me hone in on it a little this way. So how 

often do you talk with him now about getting jobs for people? 

A It varies. It can be once a week, once a month. 

It can be every day. It depends on what project that I’m 

working on. 

Q I’m trying to get an impression of both procedures 

and what groups of people you look to to try to find 

placement, how unusual it is or might be for either the 

President or John Podesta to say to you “We’ve got somebody 

here, we need to find a job for them.” 

Okay. That I can help you with. 

All right 

What’s your question now? 

How unusual would it be? How about that? 

Not at all. 

For either of them to? 

For either of them or anybody else within in the 

Q On average, is once a week fair? 

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White House. I mean, we’re a resource center and one of the 

thingsthat-Ithinkwhatwedobestisfindajob. What 

Page 26 

I A Yes. Well, no, I’d stretch it out a little more, 

2 like every two weeks. 

3 Q And how long have you had this job? 

4 A Alittleoverayear. 

5 Q Mymdime.ntarymath!zugge&thatmaybcyou’vebad 

6 25orsoconvcrsationswiththepresideataboutthat? Just 

7 as a ballpark? 

8 A I’d be comfortable with that. Sounds like a Iot. 

9 Q AndarethesepeoplewhoareintheWhiteHouseat 

o the time and you’re looking for positions for whoever they 

1 are outside the White House? 

2 A These are people that fall under the portfolio of 

3 jobs that I oversee. 

4 Q Then let’s ask tlx White House version of the 

5 question. How many mplc who work at tk White House has 

6 the President asked you to try to find a position for? 

7 A I don’t know. I don’t have any memory of that. 

8 Q Do you have a memory of that ever happening? 

9 A Of him asking me about White House people? 

!O Q Asking you to try to find a job for someone who i: 

!I then currently working at the White House. 

!2 A I’d have to go through each name and we’ve got 1200 

!3 people that work in Executive Office of the President and 

~4 I’ve been there five and a half years. 

!5 0 so YOU think - 

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Page 28 

we don’t do as well and what’s harder for us, we’re not 

geared up for it, is finding the person for the job. So we 

take input from a wide variety of sources. A place that I 

would always welcome input would be from my colleagus, 

particularly from senior staff because I’ve worked with them 

longest_ 

Q Well, he&s maybe even more specific - you look 

like you’re about to finish your answu,soplcascgoabead 

A What else I was going to say is part of that 

pw it’s not a me - it’s not tbem telling me. We have 

a group of people that work on this. So, for instance, if 

Bob Nash, who is my immediate supervisor, got a call from 

John Pod&a and it was something in my portfolio, be would 

anneztome. SoImightnothavetbed&ctcoaversationwith 

John, but I would know that John Poclesta had asked that this * 

person - that we find this person a job, if possible. 

I’ve never been told by anyone to give somebody a 

job,butIhavebeznaskedbynumerous people to please help 

find somebody a job. 

Q And that would include Podesta? 

A Y&s. 

Q And it would include @ President? 

A Probably. It’s his office. 

Q And as you’re thinking about people ti have asked 

you to do that, would you be including Betty? 

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A Yes. 

Page 29 

Q Does it happen often that you interview or chat 

with people who want TV come back to the White House from 

some position outside the White House? 

A Yes. That happens quite often. 

Q Why is it that people want to come back? 

A I think that it’s the allure - it’s the highest 

position in governmen t or it’s the place of the highest 

positions in govanmen t, particularly for young Democrats. 

It’s a once in a lifetime oppoitunity to get to work directly 

for a president. I think it’s particularly true of the 

younger people. 

Tbey want to wme back in because they were drawn 

to this by the man himself. ‘Ihey really feel an allegiance 

to both the President and the Vice President, I think ever 

more so than they feel allegiance to the sort of democratic 

principles. ‘I&y want to work for this particular president. 

And you think it’s the only shot you may get in your 

lifetime. 

‘Ibe Democrats have only held that of&z once since 

Carterandthatalmostseemslikeabliponthescreen,so 

it’s a long time between Lyndon Johnson and President 

Clinton. 

Q When people want to come back from outside the 

White House to back within the White How do you routinely 

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discourage that? 

A Yes. 

Q WY? 

Page 30 

A Well, there again, it is a once in a lifetime 

opportunity. It’s very difficult work. It takes a lot out 

of you, I tbink there’s some point you should get on with 

your life. Use it, it’s a great expcrienee -- 

Q You’re saving people from themselves? 

A Insomeways. Ilookintbemitroreverydayandl 

go, “Okay, when are you going?” It’s - it’s a building 

where expertise is not necess&ly needed. And ona you’ve 

been there and developed a certain niche, I think it’s best 

to go on and apply it, get on with your life. But I do 

encourage people to do it for the fm time if they can. I 

think it’s an exceptional opportunity. 

Q Other than Monica, have you talked to interns about 

placing them outside the White House? 

A Probably hundreds. 

Q Other than Monica, have you chatted or interviewed 

with people who wanted to return to the white House who had 

been interns? 

A Yes. 

Q Lots? 

A Lots. 

Q Do any of those people end up with jobs in the 

March 31,1998 

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White House again? 

Page 31 

A Probably. We’ve had -- particularly -- I think in 

the advance office, probably -- I know we’ve had a tu 

around, OMB people come in and out Probably in the 

communications department you’ll find examples of that. ‘II 

political office, that’s true. I mean, I’m even a case of 

someone that’s gone in and out two different times. 

Q What I’d like to ask you about next, basically, 

some questions related to the time YOU talked with Monica 

where you had a tearful session. There were some accusation 

made, there were some -- let’s call it beated discussions for 

lack of a better word. I want to talk about first the 

following. Did you talk with anybody about that afterwards? 

For example, anybody on your staff? 

A Icould answer this a lot better if I knew when I 

talked to her because my young assistant, you know, she very 

easily could have been in at least part of that first 

meeting. 

Q ~tmesuggesttoyouthatitmayhavebeenbeturen 

your &um from Paris in vay early August and approximately 

September 4th 

A That I talked to my assistant? 

Q ‘Zhat you talked to Monica and therefore. if you had 

talked to your assistant shortly afterwards, it would have 

been about that timeframe. 

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A Then I don’t think I probably did 

Q IguesswhatI’mtryingtothinkaboutis-Itake 

it you don’t often have these sorts of conversations with 

people, people crying in front of yoy tearful, making 

accusations, saying tbat otkr women in tbe office have bea 

sleepingtithtbe~~t,hcrnotbeiitreatedaswtllas 

these other women. It sounds Iike a fairly unique 

conversation. 

A IthinkitWaS Imean,thecryingpartisnot 

unique, people revealing pnsonal w that’s not unique. 

The accusation part was very unique. 

Q Andsoitwasauniquemeetingoraunique 

conversation or a unique in&lens one that was very 

emotional, I assume? 

A For Monica, yes. 

Q And one that made you a little worried about 

whether Mcmica should be baek in the white House, right? 

A It solidified what I already thought 

Q AU right_ So it ma& you worried about - it 

helped you te conclude that she wouldn’t be suitable in the 

White House. 

A I had already concluded that. It validated it. 

Yes. 

Q You knew that she had apparently come reasonably 

close to geaing a job with the National Security Council, at 

, 

Page 29 - Page 32 
3617 

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Page 3: 

I le;tst she had gotten to the second interview stage, right? 

2 A I don’t know that. I don’t know that she had a 

3 second interview. 

4 Q Ithou&htyouhadsaid~t--maybeIwasthinking 

5 of -- 

6 A That she had one interview. 

7 Q I thought you had said that there were two 

8 interviews that you knew of. 

9 A I don’t think so. 

0 Q All right. Maybe I’m ding one of the letters 

1 that I read to you indicating that there had been two 

2 intervkws. But anyway, you knew that shr: had at least 

3 followed through in order to try to get a job at the NSC. 

4 Y~~~t~~~l~a~b~~~~~t 

5 approach others. I’m just trying to think to myself if I 

6 wereinyourshoes,IbadthosCfectin&thosere&ions,I 

7 might have told somebody about it 

8 A The only person 1 can think of that I would have 

9 talked about it all would have been Betty and I just don’t 

o have a memory of doing that. 

1 Q WelI, you knew what areas Monica was intexsted in 

2 working. Would you have callal tbosc pa@e and said, “Gosh, 

3 you know, if you get a call from this Monica person, be on 

4 the lookout”? 

5 A I didn’t do that. 1 didn’t feel like I was going 

Page 34 

I tobavetos&otagcMonica. Tbepmxsstogetajobintbe 

2 white House is she would have bad to have gone through 

3 I!&cinc Bow&s. She c&d not have been hired by any office 

4 Aad I felt very co&dent that Mr. Bowles would handle it 

S correctly. And other than Monica - 

6 BY h4R. WXSeERCZ 

7 Q And why did you feel that? Pardon me for 

8 inmpting, but why did you feel that? 

9 A Becauseofthekindofpersonheis. AndMonica 

0 shows her cards really quickly. 

1 BY MR. EMMKK: 

2 Q Wbardoyoumeanby”tbckindofpasonbeis”? I 

3 don’t know how to interpret that. 

4 A He follows - he has rules for everything. He 

S follows a really strict prot5col. I didn’t - my impression 

6 was Monica was not going to get very far with the interview 

7 processintbeWhiteHouse. Ihadalreadyiearned&attbere 

K ~~~PIe~t~fe~d~~~as~. 

9 Q But how could you know whether that informatior 

0 wouldhavcbcenimp~topmpkwbowouldnadtoknow7 

1 A I didnt ’ know that. I did not bow that for a 

2 fact_ 

3 Q Weren’t you cmmned? I guess that’s really tlx 

4 bottom line question. 

5 A I felt like after I had talked to Monica, one, that 

PZlgP March 31, 1998 

Page 35 

1 she wasn’t going to try the white House route any more. And 

2 my understanding uith her W~.S that if she came up with some 

3 specific jobs that she wanted in the White House she’d let me 

4 knowandfhadatso~therknowthatithadtogothrough 

5 Mr. Bowles, which was something that my memory serves me 

6 correctly she wasn’t that interested in doing. 

7 BY MR. WISENBERG: 

8 Q You said that you were sure he would do the correct 

9 thing if it was up to him. What is the correct thing? 

0 A Well, I thought the correct thing would be she 

1 wouldn’t get another job in there. 

2 BY MR. EMMICK: 

3 Q what gave you the impression that she wasn’t going 

4 to follow up with the Erskine &>wies idea? 

5 A- Monica was not happy with me because I had not done 

6 it, I had not gotten her a job. Particularly after I talked 

7 to her the last time, my memory of the conversation with her 

8 was-- and I think I told you this bcforc -- Monica was ; 3. 

9 persontomethatactedlikeshewasentitIed. AndwbenI 

0 let her know that s!x wasa’t entitled to a job again, she was 

1 very unhappy about it and she tried the gamut of emotions, 

2 from being tearful and upset to being angry and petulant. 

3 Do you know the Miss Peggy character? 

4 Q 1 know her well. 

S A That’s a characterization that I would give to 

Page 36 

4 

. I 

)j 

1 Monica of beiog extnznely charming and tkn the minute sk’s 

2 not getting her way, &en this whole other side. And that’s 

3 not that unusual in some young people. 

4 Q Inmymind,onereasonthatyoumighttalkwith 

5 othasaboutthca&n8tbatyoubadwitbMc&awouid&to 

6 tXpmSGoncernthatshenotbehired 

7 Another fkasxm might be it’s a pnztty strange 

8 conversation that you had had with her and just in the 

9 same way that you% taIking with friends and colleagues’ 

o about, “Gosh, let me tell you what happened today,” I 

1 would think that you might have said some&@ about it. 

2 “Awo~~~~t~~~~~d~~~~ 

3 we had this heavy duty conversation, allegations were 

4 flying, let me tell you about it” Did you have anything 

S like that? ‘ 

6 A I don’t treat the people that come and taIk to7 me that way. I xeally see them in some ways as clients, 

8 I guess, in a loose term in that I think that’s kind of 

9 gossipy. I think if I had talked about it with anyone it 

0 wouldbavebeen&thBettyCuniebecauseBettywasber 

I friend_ 

2 If I had been unduly al@ that Monica was 

3 actually going to go anywhere with this quest within the 

4 White House, thm 1 probably would have acted. I didn’t feel 

5 that kind of alarm. I was appalled at what she said. 

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Page 37 

I also believe that less said about trash the 

better because sometimes a lie, if you start repeating it, 

tlx lie then becomes a fact. I think this investigation is 

lx.zd on a lot of that kind of rumor that’s now accepted as 

fact. 

My gut, my instinct around Monica, in dealing with 

k. was that it was finished as far as the White House part. 

She was angry at me. I felt like she was going to dump that 

anger on me, but I didn’t see it going anywhere else. She 

hadn’t done anything else I’d asked her to do, so I saw no 

reason that she would pursue anything else. 

Q Did you talk with Patsy Thomasson about your 

meeting with Monica? 

A No. The only thing I remember about talking with 

Patsy Thomasson about, I think, was the whole concept of the 

detail and I know that I talked to Patsy and to Liz Bailq 

about the whole detail idea and I had told them I was backing 

away from that. But I don’t think I’ve ever shared with 

either Patsy or Liz any details of the conversations I had 

with Monica. 

Q Let’s turn to the Patsy Thomasson discussion about 

the detail, then, because I have a couple of different 

possible interpretations of what happened and you tell me 

utich is right and which is not, because we had one source of 

information that indicated that Patsy Thomasso n said that 

Page 38 

there was a detail but that what she really needed was a 

worke!r and not a loiterer and since one way of interpreting 

clutch or stalker is as a loiterer, it makes me think did 

Patsy say there isn’t a detail, let’s not even think about 

it, or did she say there is a detail, but that’s not the kind 

ofpcrsonIwantbecauscIn&dsomcbodywhosgoingtocrank ’

the hours rather than hang out? 

A I’m not sure what you’re referring to. That’s not 

a coaversation I ever had with Ms. Thomasson, but Patsy had a 

number of details unclu her which sbc may bavc boxy dating 

to. 

QIsee.’ 

A I don’t think - I am quite confident that 

scenario you just laid out is not anything Patsy shared i 

with me. 

Q I see. So the discussion that you were talking 

about when you said the detail was gone, that was the detail 

that you had under your supenrision and Patsy may have had 

o&r details possibly in mind in thinking, well, maybe we 

could find some place for Monica? 

A I have absolutely no memory of ever talking to 

Patsy Thomasson about helping Monica find a job of any sort 

otk than when I was finding out about the detail for my 

offke, which was the women’s office. At the same time, we 

had a number, or what we thought we were going to have, a 

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number of detailee jobs. 

Patsy could have in subsequent conversations with 

Liz Baib, who was the person Monica had to work ui& could 

have thought of other possible details in our office. Tha 

could be referring to what you’re talking about. Those also, 

I think, dried up and were just not legal or whatever the 

word - they werent ’ there. 

Q Another way of asking the question is any idea 

where Patsy got the notion that Monica would be a loiterer? 

And I was thinkiq to myself that that may have been in a 

conversation you bad with her and you’re suggesting maybe 

it’s a conversation Ms. Bailey had with her? 

A I don’t know who - I mean, you’re playing let’s 

think of scenarios. 

Q iiun. 

A Iwastryingtothinkofascenario. Thatwasnot 

my scenario. I didn’t have that conversation that I know of 

or have any - 

Q And Patsy didn’t ask you about Monica? About 

“I’ve got another possible detaiI for that Monica person you 

mentioned the ok day, do you think she might work out?” 

Anything Iike that? 

A She could have, but I don’t have a memory of that 

MR_ EMMICK: Okay. 

‘IHE FXXEI’ERSON: Mr. Emmick? 

hfREMMIC& Yes? 

THE FORJXPERSON: It’s time for the grand jury to 

takeabrezxk. 

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Page 4~ 

mm Timeforabreak. 

THE FOEUZPERSON: Just a ten-minute bnzak. 

MREMMICK: Aten-minutebreak Allright I 

have- 

-” 

TKE WlTNESS: Do you know how much longer - 

hSR_ EMh4ICX I don’t think it will be much longer, 

butlTHE wll~~~: Is much less than more? Five 

minutes? Tenminutes? Thirty? 

MREMMI~ rwouldguess-Iwouldgucssinthe 

neighborhood of 15 minutes, but I can’t - you can’t hold me 

to that_ 

MR. WISENBERG: We cant ’ promise. 

MR Eh%ucx Carl? promise. Butthatwouldbemy 

best guess. We’re also going to ask you to m out and 

we’ll ask whether the grand jurors have questions. 

THE WITNESS: Okay. 

MR EMMxtx so there may be some other follow-up, 

but if I had to make a best e&mate,it would be 15 minutes 

TIE WITNESS: Okay. So we’re taking how long of a 

break? 

h4R_ EMMICK: A ten-minute break. 

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THE WlTNESS: Okay. All right I’ve got all that. 

(Witness excused. Witness recalled.) 

MR. WISENBERG: Madam Foreperson, do we have a 

quorum? 

March 31,1998 

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, 

that ability. ! 

Q Did she say Betty or arc you concluding Betty baxd 

on the fact that it was Betty who made the call? 

j 

/ 

A I don’t remember her Saying ht. I’m just playingj 

THE FOREPERSON: Yes, sir. We do. 

MR.WlSENBERG: kethereany unauthorized persons 

in the grand jury room? 

THE FOREPERSON: No, sir. There are not. 

MR. EMMICK: Let me remind you -- 

THE ms: Yes, thank you She did. ‘Ihank you. 

MR. EMMICK: She did? 

THE mfzss: she did. 

MR. Eh4MICk The WitneSS has been tinded. 

BY MR. EMMICK: 

the hypotheticals like we have been. 

Q Did you ever see or hear anything while you were at 

the White House, you still are at the White House, to lead 

you to believe that there was something inappropriate going 

on between Monica Lewinsky and President Clinton? 

A I didn’t see anything, hear anything. 

Q No rumors? Nogossip? Nowhispered discussions, 

anything like that at all? 

A Correct. 

Q Let me ask you this. Ln the heated conversation 

that you had with Monica, did Monica ever accuse you of not 

doing what the President wants you to do? 

A No, I don’t think so. 

Q Did she ever say anything like “The President told 

me that he was going to have you get me a job and you’re not 

doing it”? 

Q All right. Did the President ever ask you to help 

Monica in any way? 

A No, he didn’t. 

Q Did Monica’s name ever come up in a conversation 

between you and the President? 

A Not that I remember. No. 

Q Is it the kind of thing that you would have 

remembered? 

A I think she may have said that about Betty. I 

don’t -- you know - 

Q Did the President’s name come up? 

A only in the context Of the Women, that 1 I-emZIber. ’

A No. Probably not. I don’t know why I would 

remember it, unless he was giving me a direct order on 

something, to specifically do something. I don’t know why -. 

Q If the name had come up, would you have known who 

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MR. WISENBERG: IjuSt have a clarification. 

BY MR. WTSENBERG: 

Q Whenyousayskmi&thavesaidthat&outBetty, 

thatshemi&thavesaidthataboutBetty,doyoumeanthat 

Be#ysaidsbewasgoingtotalktoyouorthtResidcntsaid 

hewasgoingtot.aIktoBetty? 

A Betty. NothingtodowiththePresident. That 

Bettybadtalkedtome. SheknewBettybadtalkedtome. 

BY MR. EMMICK: 

Q And that you weren’t doii what Betty wanted you to 

do? 

A And what she wanted. It was more what Monica 

wanted. Monica really felt like she was entitled to come 

backinbecauseshehadbeenwnmgedinthefvstplaceand 

thatwaswrong. IdontkMwthathkxlicawaspromiscd8job ’

by anybody. 

Q Was the tone of it that in addition to not doing 

what Monica felt she was entitled to, was the tone of it 

“And you’re not doing what Betty asked you to do”? 

A What she thought I was supposed to do. 

Q Because of what Betty had asked. 

A I think Monica clearly believed that because she 

wasthere,becauseBettyCurriehadsenthertome,thatshe 

had a clear in and I think she also believed that I had the 

ability to get her a job in the White House. I didn’t have 

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he was talking about? 

A I would not have. 

Page 44 

Q Ifthatnamchadcomeupafkryourinterviewwitb 

Monica, would you have remembered it? 

A Yes. WelI, I don’t know if I would have or not, 

but probably. 

Q But you don’t think the name did come up. 

A No. I think I told you before, I really - I don’t 

remember having a cmversatim with him about it, but it 

wouldnlthavebccaunusualiflhadmntiooedtohimthatl 

hadseenherorthatBettyhadaskedmetoseeber,butIdo 

not have a memory of that conversation with him. 

Q Do you have any impression that the President might 

bavebeenintenstedinwbethaMonicawasabletogetajob? 

A I don’t have any memory of that impression. No. 

Q You indicated that - 

A I’m sorry -- 

Q Go right ahead. 

A I was going to say a lot of this is so polluted by 

what I have subsequently heard and read. 

Q We’ve beard other witnesses say that same thing in 

almost those same words. _ 

A Really? 

Q Did you ever give any impression that persons in 

the white House had either issued a directive or issued some 

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sort of instructions or some sort of strong hint that Monica 

Lewinsky shouldn’t be permitted back? 

A No. I would think the -- well, I can only speak 

for myself. You know, I certainly didn’t think she should 

come back and I think that I indicated that to Liz Bailey and 

I probably indicated that -- well, to Liz, who was her -- 

Q I guess I have a slightly different timeframe in 

mind. That is to say, as you were nosing around a bit tc 

find out whatever you could about Monica by talking to NSC. 

by listening down at the mess or in whatever ways you might 

did you ever get the impression that the word was out that 

Monica shouldn’t be rehired? 

A No. 

Q There is an e-mail that IIMkeS IZfeXCmX t0 the 

fact that if Monica should come back or should try to come 

back various people should be talked to about the situation. 

Do you know anything about that e-mail? 

A No. Sounds interesting. 

Q Did you ever talk to Bruce Lindsey about Monica 

Lewinsky? 

A No. 

Q You m&ioned that when you, for lack of a better 

word, reported back to Betty about what had happened in you 

discussions with Monica and you had told her that -- words tr 

the effect that she had developed a reputation as a stalke 

Multi-Pagem March 31,1998 

, 

5 Page 47 

1 of “You ought to tell your friend that chances are it’s not 

2 going to happen”? 

3 A I think -- I don’t think I said that to her, but I 

4 certainly let -- I’m sure that I would have let Betty knou 

5 that I wasn’t going to help Monica in that way, but I wa 

6 delighted to help her get a job elsewhere if she was unhappy. 

7 And the term that I would have used in that is to walk her 

I 8 down, to back her off. 

9 Q of? 

, 1 0 A Wanting a White House job. Because I was clear 

1 1 about her not getting a White House job. 

1 2 Q Had you been able to get positions for the other 

1 3 people whom Betty had asked you to help? 

1 4 A If I could remember who they were, I could tell you 

1 5 whcthe~ I had or not. 

1 6 Q Do you have an impression that you were able to get 

1 7 help for those people or are you hesitant to say without 

1 8 having their names in mind? 

1 9 A I don’t have a clue who we’d be talking about_ 

2 0 I don’t know what my success ratio is in getting jobs. 

2 1 Q fl right. 

2 2 A In the White House, it’s probably almost zero 

lr2 3 because I don’t get jobs unless they’re in our department. 

12 4 Q In the conversation with Betty, did she say 

:r 2 5 anything about any discussions with Mr. Pod&? 

i Page 40 

A No. I was actually surprised when I heard John 

Podesta’s name through one of the media sources, 

Q Surprisedwhy? 

A &.tstwassuquised 

Page 46 

or “The Stalker” you said that one of Betty’s reactions was 

“Oh, clear.” Or might have been something like “Oh, clear.” 

Do you remember that? 

A Could have been. I mean, that’s how Betty reacts 

to things. 

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Q IguessIwasgOingtotrytoeXplOre~atOther 

things she might have said in reaction to tbe telephone 

conversation you had with her or the meeting that you had 

with her. Other than “Oh dear.” 

A I just don’t have a memory of that conversation, 

but that’s how Betty responds to most things. But I’m 

willing to listen. 

Q Did you say anything like, “This just is not going 

to happen, you ought to tell your friend it’s not going to 

happen, sk’s not goiing to get back to the white House”’ 

A I don’t know that I would ever have been that 

specific because it wasn’t up to me whe%lxr Monica got a job 

in the White House. Monica was not going to get a job with 

me in the White House. 

Q But wouldn’t your best estimate have been she’s not 

going to get a job in the White House? 

A Based on what I think I know of Mr. Bow& I would 

have said that and I believe that, but I wouldn’t have stated 

that because 1 don’t know that to be a truth. 

Q Would you have said something more along the lines 

Q Is this because you felt if that had happemcd you 

would have heard about it sooner? 

A 1 think wh+? was surprised, John’s sort of 

taciturn, he’s q&t. I don’t know. I just had ncvcr 

, thought about John in that context of finding jobs for 

II people, although I’m sure he does that because he’s workai 

1 bcrealongtimeandhec&ainlyhasagreatintuestintbe 

1: personnelpmcessandhas recommended a lot of people from 

1: the Hill. 

11 Q Would it strike you as unusual if there were 

? 1. several people in the White House who had bax~ quested to 

lr help Monica find a job? 

1’ A There’s a lot about what I have read about that has 

11 surprisedme. 

l! Q What would strike you as surprising or unusual 

21 about there being several people at the White House, 

2 including y&-self, John Podesta, maybe others, trying-+- 

2: find a job for Monica Lewinsky2 

2: 

21 

21 

A we& now - I can only speak for now, because I 

don’t know how I reacted wlxn I first -- first of all, I I 

don’t know what I believe. I don’t know what’s true in this 1 

Page 45 - Pa& 45 
3621 

Page 45 

Pagem March 31, 1998 

Page 5 1 

1 at all. If there were other people helping Monica, it fits I Q Having in mind that all things being equal, you 

2 with the aggressive side of her that I saw and her tenacity. 2 would prefer not tn make Mr. Kaye unhappy or Betty unhappy, 

3 And it also fits with the fact that she was very unhappy at 3 do you think that part of what was going on here was that you 

4 the Pentagon and really wanted out. So that part of it, the 4 were stringing Monica along, not getting her a job, saying, 

5 surprise would be that the kid can go so far so fast. 5 “Well, you never know, I’ll keep my eye open,” trying to put 

6 Q so it didn’t surprise you that th!xe were a Couple 6 Monica off, on the theory that Monica would drift away of her 

7 of pmpk in t& white House working simuIraneo~ly on trying 7 own accord? 

8 togetherajob? 8 A I wouldn’t characterize it that way, but, as I 

9 A No, all that, everything about this has surprised 9 said earlier, I did not want Monica being unhappy about 

o me, but when I step back and think of my impression of :O the whole process and she was a young person that was 

1 Monica, it’s kind of - it’s pretty pushy. , 1 clearly unhappy. She had very harsh words to say about 

2 Q So you think Monica arranged for those different 2 Evelyn Lieberman in particular and her experience on Faust 

3 people to be helping her? 3 leaving. She seemed very unhappy. I did want to calm her 

4 A Well, that was my assumption. If indeed it’s true. ,4 down in that respect and I didn’t want to totally close the 

5 I don’t know that it’s lnte. s door-on her. 

6 Q I guess I’m just - you know, I wasn’t at the 6 While I did not want Monica working for me or 

7 White House, so I don’t know how unusual it is to have 7 working in the White House, I was not at all opposed to her 

8 people at the level of yourself or of John Podcsta or 8 working in another job in governmen t and would have been 

9 of others, maybe even Mr. Nash, working to find a job 9 happy to have helped her with that 

o forsomeonewhohadworIcedattheWhiteHouseforallof 10 Q Would it have been fair for a person in Monica’s 

I four months. !l position to interpret what you were doing or were not doing 

2 A I can only speak for myself and what I know and, :2 as stringing her along? 

3 more spccifically~ what I know about bow Bcb Nash works and 13 A I don’t know how she interpreted it other than I 

4 how I work. Two factors. One, Bob in particular will see :4 understood she was irritated with me, probably even angry 

5 anyone, just ahout anyone that makes a request. That’s one .S with me, because I didn’t do what she initially wanted. 

Page 50 

I of-mjokewithhimthatoneofhisprublems,heseesway 

2 too many people. 

3 I also am very accessible to seeing people, 

4 particularly the junior people, that others don’t have time 

5 to see. I think it’s important to mentor ynung people and to 

6 get t.Izm involved in the process. So for Bob and I, it’s not 

7 vayunusualforMonicaoranybodyclsetohavesecnus. 

B For other people in the White House, we’re not a 

9 particularly rigid, Gxarehical place, although Hr. Bowles 

o has tried to institute more of that. But particularly those 

1 ofuswhohavebeen~~alongtirne,there’sareal 

2 allegiance to people who we have known or who are friends. 

3 So in Monica’s case, being almost a protege of 

4 Walter Kaye who is a good and close friend of many of us in 

5 the White House, it is not at all unusual that someone 

6 involringhisaamcwouldgetinandbaw:anynumbcrofprivatc 

7 audiences with senior staff. That is not at all unusual. 

B Q Do you think it’s driven more or might be driven 

9 more by Mr. Kaye’s stature? 

3 A Based cm my observations of Monica, I am sure she 

I used Walter Kaye in any way that she could. And anyone thar 

2 knows us knows of our closeness to Walter Kaye and that he? 

3 a&lightfulmanandthatwedoalotofthingswithhimand 

4 would go - any one of us would go out of our way to take 

5 care of people that were important to Walter. 

Page 5 

1 Q Were you at all worried that Monica was potentially 

2 a loose cannon? 

3 A Should have been more than I was. 

4 Q what do you mean? 

5 A Hindsight. 1 wish -- I don’t know what I wish P 

6 loose cannon? No. I never in my wildest ever would have 

7 predictedallthe%rfTthathasspewedoutaroundMonicaaw 

8 thetalesthathavebeentold. Never. lfIhadthoughtt.hat 

9 in one instant, I probably would have asked that she be 

0 committed 

1 MR. EMMICR Interesting. 

2 Any other questions that you have? 

3 MR. WISENBERG: Me? 

4 MR. EhiMICK: him-hmm. 

5 MR. WLSENBERG: A few. 

6 MR. EMMICK: Okay. 

7 BY h4R. WISENBERG: 

8 Q You had mentioned, I think, the first time you were 

9 here the session that got to be not a happy one and Monica 

0 was talking about the other women who had been protected. 

1 Did you get from what Monica was telling you that Monica 

2 implied that she had had some ki?d of relationship with the 

3 President? 

4 A No. She was most adamantly saying she had not 

5 And that’s what her anga was. Sbc thou&t that wuc rumors 

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Page 53 

about these other women and why were they still there and sh 

had lost her job and she had done nothing wrong. 

Q This is a slightly different question than the one 

hIike asked you, which is did you ever hear, obviously based 

on what you’ve said, you wouldn’t have beard it directly fron 

thz President, did you ever hear from anybody that the 

P&dent had asked about a job for Monica, getting a job for 

Monica? 

A No, other than what I’ve since read in the press. 

No. 

Q I’m not including what you’ve read in the 

newspapers. 

A No, I have not heard that. 

Q Walter Kaye -- I have a Walter Kaye question. 

Did you ever hear that Walter Karc had ma~tiomd tn anybody, 

directly or indirectly, anything about phone calls between 

Monica Lewinslcy and the President? 

A Phone calls between Monica and the President? No. 

MR. WISENBERG: That’s all I have. 

Do we want to ask the witness to step outside for 

a moment? 

MR. EMhTICK: That would be my suggestion. 

Could you step outside for just a few minutes? 

THE WITNESS: All right. 

h4R. EMMICK: We’ll see if there are any more 

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Page 54 

questions from the grand jurors. 

(Witness excused. Witness recalled.) 

THE FOREPERSON: You are still under oath. 

THE WITNESS: Okay. 

MR. EMhfICK: One of the grand jurors had a 

question. 

THEwJTNE%: Yes. 

A JUROR: You apparently were concerned about 

Monica’s unhappiness at her situation. What did you expect 

would happen if she became unhappier? Would there be an 

impact on the White House? And, if so, why? 

THE WITNJZSS: Ireally hoped that I had been 

pasuasivc mougb with Monica that sk would drop tht notion 

of pursuing anything in the White Houz, but I left open the 

fact that I really watited to help her if there were other 

things she wanted to do. And I also hoped that she would 

actually call me if there were otbez things. And then once 

that was over, I really forgot about Monica. 

A JUROR: so you weren t ‘ comxned about what she 

might do or say to create a problem? 

THE WJTNBSS: No, I wasn’t_ I mean, she - other 

than one conversation and just kind of a general impression 

3 of her, I wasn’t very alarmed about her. No. 

4 BY MR. EMh4X-X: 

5 Q I thought you had mentioned once before that you 

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Page 55 

wu-e. a little concerned that because on occasion employees 

have left the White House under less than happy terxns, they 

were disgruntleci, they would say things that would cast tbz 

N’hite House in a poor lit. Did you have any of those kina 

of concems as to Monica, who had left the White House uzxie 

unhappy circumstances? 

A I think -- maybe I didn’t say it specifically in 

answer to his question, I really felt like I was somewhat 

persuasive with her. I hoped that we had reached a pain 

where her anger was directed more at me. 

Q But that’s after you exercised your persuasive 

PO==. 

A Right. 

Q Before you tried to persuade her, was the nature o: 

one of your concerns what she might say if you didn’t 

persuade her? If you didn’t -- 

A No, I don’t think I thought of it in those terms. 

Q So you didn’t think that she would be one of the 

disgruntle former employees who left under less than happy 

terms and might for that reason say something not 

1 complementary about the White House? 

2 A I think it’s okay if you say something 

3 uncomplimentary. I never fathomed this kind of stuff would 

4 spew out. So, no, I was not unduly alarmed that she would 

5 be - she could be disgruntled and that was okay. 

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Q But it’s not something that you wanted_ 

A Didn’twantiftriedmybesttohelphtrseeall 

sides of it, to talk her through. 

Q Regardlessofwhethershehadarighttobe 

disgruntled or had a right to say things that wue not 

favorable to the White House, I assrmreth0twas!Gom&ng 

you’d prefer not l%ppen. 

A ofwurst. 

Q Andwasyourefforttotrytopermadeheraadmake 

herundastand~effo~totrytomake~that~didn’t 

go out and bad mouth the White House? 

A No. Idid.n’ttalktoherinthoseterms,butit 

wasmoreof-IthinkIwas-asItalkedaboute.arlier, 

I think I was fairly realistic with Monica, that in 

essdlee she needed to grow up, that sometimes things happen 

inlifetbattheydon’tcomeoutthewaysyouwantMdyou 

justhavetoaccepttiandgoonandshehadagood 

position,hadagoodfutureaheadofberandgetoawithit 

and just sort of chalk this up as a difficult time for her 

and go on. 

BY MR. WISENBERG: 

Q So you weren’t concerned: I just want to make 

‘ 

surelunderstand. Youweren’twncernedwhenyouww 

discussing these things with her that she might fail into 

this disgruntled former employee status and cause trouble for I 

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the White House. 

Page 5: 

A Two pieces of that. I thought she was a 

disgruntled former employee. It never in my wildest ever 

occurred to me that she would do anything relating to that, 

other than what she was doing, which was she wanted to get a 

job so that she could reprove herself, I guess. 

A JUROR: I just had one qu&OrI. 

At what point did you heunne aware that Monica was 

a friend of Walter Kaye? 

THE wrrNEss: I think immediately. 

A JUROR: And was there any special -- oh, I don’t 

know, was she given pnzfmtial treatmentbecausesbewasa 

friend? 

THE wrrmss: Let me answer the first part_ I 

think that Monica probably told me about Walter. I don’t 

think Betty Cunie did, but I think Monica did and we had 

discussions about him and I think she -- I think she ever 

refers to him as “Uncle Walter” or “be’s like an uncle,” 

that’s a memory I have. 

Now, your second part of your question was did she 

get preferential treatment. Only in the sense that I like 

Walta very much and would bavc gone out of my way to make 

sure that I eventually could see Monica, even if I was very 

busy, I would have made that effort for her. And would have 

based on my liking of him. If she had worked out, that woulc 

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Page 58 

have been wonderful and I would have liked to have worked 

something out for her on the basis of the fact that I like 

himsomuch 

BY MR. WI!SENBEXG: 

Q Did the President ever ask you to help find a job 

for David Watkins? 

A God, that was even longer. Good question, Sol. 

I have to go fmd out something. Just a second 

(TAX witness was excused to confer with counsel 

at 4:00 pm.) 

****** 

Whereupon, (4: 15 p.m.) 

MARSHA scol-r 

was recalled as a witx.ss and, having been previously duly 

sworn by the Forepeison of the Grand Jury, was examined ant 

testified further as follows: 

EXAMlNATION (RESUMED) 

MR. WISENBERG: Let the rtxd reflect the witness, 

Marsha Scott, has reentered the grand jury room. 

THE FOREPERSON: Ms. Scott, you’re still under 

oath. 

THE WITNESS: Thank you. 

BY MEL EhM.ICK: 

Q What was that question again? 

A What was it? 

PageTM March 31. 1998 

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BY MR. WISENBERG: 

Page 59 

Q Did the President ever ask you to help David 

Watkins find employment, find a job. 

A I remember the President asking me to help 

David, but I don’t remember being asked to help him find 

a job. 

Q All right. And do you remember about when t!!t 

was? 

A It would have been around the time David was 

leaving the White House, which was - you know that, I think. 

Q somewhere in ‘94. 

A Is that when it was? I truly don’t remember that_ 

Q Whatdidyoudo? What, ifanything,didyoudoto 

help can-y out the President’s wishes? 

A- I was a friend of Mr. Watkins then and I was \try 

concerned about David’s mental state, particularly in light 

of when Vince Foster killed himself. I would have though: it 

would have ~WI David, not Vincc. He was a vay high strung 

personandIknewthathewasveryunhappy. AndIspenr 

extra time with David, if I could. 

Q Let me just ask you this. Did you make any efforts 

to help bim find employment? 

A No,1 didn’t. 

MR. WISENL3ERG: You had some questions, Mike? 

MR. EMMICK: Yes. 

1 

2 

3 

4 

5 

6 

7 

B 

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BY MR. EMMICK: 

Page 60 

Q You mentioneal that you knew Betty Cunie and Monica 

to be friends. 

A 1believesO. 

Q How&dyouknowthautobcfr&ds? Whatma&you 

think that? 

A ~thi&~IidiC.i3tedbtfO~wkn&ttycurrie 

callaimeorwhuiMonicafirstcallaime,someoneiIlt& 

b&nning,IgottbetwoofthemlinkedupandIknowIhad 

subsequent conversations with Betty, at least one or two 

probably, about Monica. And then when you use the word 

friend, I mean, I don’t know how Betty defines that. My 

impression certainly was that Monica was =n==wBeffy 

cared about, liked, and wanted to help. 

Q Do you recall bow Betty referred to Monica? 4 

Wtrdbashcuscdtkwardfricndorwhlbaskusaltkword 

good friend or did sbc use the word somebody I’m close to? 

What was her cbamcterization? 

A I don’t remember that 

Q- But the irdprcssion you got was - 

A This was someone that she cared about. It wai a 

young person. Betty took a lot o-f young people under her 

wing and that’s my impassion of wkc Monica fit with Ektty. 

Q How good friends are you with Debi Schiff? 

A ClOSe. 

Paoe 57 - Paz: 60 
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Page61 

Q he of your better friends there at the White 

House? 

A Yes. She’s one of my favorite people. 

Q How long have you known her? 

A Since: ‘92, I think. Yes. Probably -- I don’t 

think I met her in ‘91, I think ‘92. 

Q How good friends are Debi Schiff and Betty Cunie? 

A They’re close. I think I would define it tlrzy work 

very closely together, daily, or used to, and occadonally I 

think the couples probably socialized in larger groups with 

other couples. 

3624 

MUlti-PagCTM March 3 1, 1998 

I Page 63 

1 THE WITNESS: Thank you. I appreciate it. 

2 MR. WISENBERG: This is it barring any further 

3 evidence that is uncovered that would cause us to call you 

4 back. 

5 THE WlTNESs: I expected you to say that. 

6 MR. WENBERG: All right. 

7 THE WlTNBSS: Thank you. 

: 8 THE FOREPERSON: Godspeed anyway. 

9 THE WlTNBSS: Thank you. 

I 0 (The witness was excused.) 

1 1 (Whereupon, at 4:21 pm., the taking of testimony 

1 2 inthepresenceofafullquonnnoftheGrandJu.tywas 

1 3 concluded.) 

1 4 ***** 

MR EMMICK: Any other qX&JnS people wanted to 

ask along those line-s? 

Yes, sir? 

A JUROR: Could you tell me, please, do you have 

formal training in psychology and, if so, what courses you’ve 

taken and where? 

THEWITNESS: Ihavehadanutnberofpsychcourscs 

and I took them at University of California at Santa Crux 

Actually, my favmite one was “Psycholcgy and the Lsw.” I’ve 

takenallthebasic-Psych 101,102. Iwasapreschool 

teacher and I was a certified preschool teacher and unde 

that I took a number of early childhood education courses. 

I taught preschool, taught a number of training programs for 

expectant mothers and took refresher courses all the time in 

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Page 62 

that. It’s a long time ago, I’d have to go back and look at 

the transcripts to give you exact names, but - 

A JUROR: Thank you. 

BY MR. WISENBERG: 

Q Did you tell Debi Schiff about your interviews with 

Monica LWhlsky, particularly the OIlc & she narrpd Mmcs? 

Where Monica named names? 

A Idon’tlmowifIdidornot,eventhough~namd 

Debiinthat. It’s-thereare-thereamsomanywild 

things that are said about any number of us in the White 

House that if - my position has been if I indulge in that 

thenitdrives~crazyandIknowhowIfeclifpeoplecome 

to me and tell me that they just heard that I was sleepiq 

with alligators in New Orleans, it’s hurtful. I don’t always 

pass on all that kind bf information. So to get to your 

answer,Idon’trcmem berwhetherIevertoldD&iSchiffthat 

or not. 

h4R WISENBERG: Any further questions? 

(No response.) 

MR- WENRERG: Al right. 

MR_ EMIvtXcK: May the witness be excused? 

THE FOREPERSON: Yes, she may. 

‘IwE wrrNEss: Is this it? 

MR_ EMMICK: I think this is it. 

lHE FOREPERSON: This is it. Godspeed. 

Page 61 - Pa% 63 
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_____. -.-_ - -. ___~~_ ._. -- .- 

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____-_- 334 328 329 330 331 332 333 

NOVEMBER 1997 7540-01-337-4703 

For 1996 Order 7540-01-337-6712 

KNOW YOUR RIGHTS OPTIONAL FORM 5067-126 67 

(Formerly Ad-300) 
SUN. I MONDAY I TUESDAY I WEDNESDAY I THURSDAY 

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SUTPHEN 1 l/19/97 11:28 &DO:48 WASHINGTON D 13 - 0. 

82%DC-ooooooo4 
Durallon From Phone From Nomo ToPhone lo Name 

--.____ 

- 

w:oi:w (?0$697-9311 LEw~NsKY. MONICA; DONOVA<JZG (212) 4154492 WATKINS, ls~eEL -)__---/- --_--I __.-_-_I-.~-- 

W:W:49 (703) 697-9312 LEWINSKY. MONICA. DONOVAN, JOHNlP (212) 415-4492 WATKINS, ISABEL 

-__ 

W:OI:W _ (703) 697-9312 LEWINSKY. MONICA: DONOVAN. JOHN/P (212) 4154492 WATKINS. ISABEL 

L--2_--_--.-- .__- I- I v W:W:66 (703) 697-9312 LEWINSKY. 

.-_- -__ -- .L--__.-_ ___- -.___ _.___ __ ._._ -----.--~- 

EST 00.01 :W l2921965-6355 I LEWINSKY. MONICA 

. 

EST W:OI:W (703)697-9312 LEWINSW, MONICA; DONOVAN, JOHN/P (212) 415-4056 UN EXTENSION 

____-. .---- -_. - 

EST W:O7:W (703) 697-9312 LEWINSKY, MONICA; DONOVAN, JOHN/P (212) 415-4029 SUTPHEN. MONA 

._-- - -.-___ 

W:M:W (703) 697.9312 LEWINSKY, MONICA; DONOVAN, JOHN/P (212) 4154929 %%i?mi-- 

---- ---_- .-.-l_. -.-_--- __.-._ - __..__. ..-- -._. .-.- . . .._-_ ._--. -__I-.-_- . -.. --- 

EST W:M:W (703) 697.9312 LEWINSKY, MONICA; DONOVAN, JOHN/P (212) 415-4656 UN EXTENSION 

- .--- _-- ___-- .__---_---- --.- .-.----._---- ..- -__-.--- ---- ------- 

W:O3:W (703) 697-9312 LEWINSKY, MONICA; DONOVAN, JOHN/P (212) 415-4058 UN EXTENSION 

-- 

EST W:OtJ:W (703)m LEWINSKY,MONiG;DONOVAN,-.lGHNiP (iii) 415ZG l&i EXiENSiGi - -~~. .-. - 

_ ___ ..__ _._ .._..-. ._- _..__ -.--_. - ___._ __- ________. -- _.._._-.. .-.. _ .-___._.- _.-_. ._. - . ..- ~_._._ ..-.-. -- 

EST W:OI:W (703) 697.9312 LEWINSKY, MONICA; DONOVAN, JOHN/P (212) 415-4058 UN EXTENSION 

W:O~:W _ FINERMAN,D 

- y_ SUTPHEN,MONA __------ -- _ 

-.--__. ___~ _~_ - 

Call ID 

42191 

___. 

40081 

42196 

__ - - . _ 

40166 

44557 

___-- 

40169 

44558 

46939 

49792 

40941 

49634 

46943 

--.. 

49036 

__ _ - - 

26930 

__-- 

26556 

--- 

46969 

26994 

-_ 

49972 

--- 

40963 

256m 

40960 

--_ 

25753 

--___ 

25596 

- --_._ 

40995 

25342 

41003 

24091 

24064 

41424 
3632 

2 November 1997 

Dear Betty: 

I hope you had an enjoyable weekend. I thought Id ’ drop you a note since its ’ so difficult for both 

of us to talk at work! 

I became a bit nervous this weekend when I realized that Amb. Richardson said his staff would 

be in touch with me this week. As you know, the UN is supposed to be my back up but because 

VJ has been out of town, this is my only option right now. What should I say to Richardsons ’

L 

people this week when they call? I had mentioned to Richardson that working there was one of 

the things I was looking at. It probably sounds stupid, but I have absolutely no idea how to tell 

them, “Im ’ not sure yet”, in a business-like manner. If you feel its ’ appropriate, maybe you could 

ask “the big guy” what he wants me to do. Ahhhhh...anxiety!!!!! 

Also, I dont ’ think I told you that in my conversation last Thursday night wlth him that he said he 

would ask you to set up a meeting between VJ and myself, once VJ got back. I assume hell ’

mention this to you at some point - hopefully sooner rather than later! 

I am enclosing a copy for VJ of the list of advertising/PR firms that I included in She big guys’” 

packet. My hopes are that one of the names will jump out as a place where he (VJ) might have 

a contact. 

I mentioned to him that Id like to drop by on Sat. to give you your birthday present and to see 

him for a bit. He seemed somewhat receptive and said hed ’ check it out this week. Of course, 

hell ’ forget because in the whole scheme of things its ’ not that important and I will, of course, 

probably have to bug you towards the end of the week with this (something to look forward to Im ’

sure)!!!!! 

I hope to hear from you soon with some guidance. I am mailing my “thank-you-for-meeting-withme-letter to Richardson today. I was pleased the UN interview went well, but Im ’ afraid it will be 

like being at the Pentagon in NY...YUCK! PLEASE let me know what to do soon!!!! 

1,000 thank yous. ’

Hugs n’ kisses, 

MSL-ss-DC-9179 
3633 

CA Davis 

From: Lewinsky, Monica, , OSDlP 

Sent; Wednesday, November 05, 

To: CA Davis 

Subject: RE: troubs? 

OK. I have some bad news. I am off the next trip so i wont ’ be coming to 

Tokyo. I am probably sorrier than you are. the truth is it would have been 

so dicult to spend time together and it probably would have benn more 

frustrating than anything. 

The job thing on Friday went much better than expected. It was nice; the 

big creep called thursday night and gave me a pep talk because i was so 

afraid Id ’ sound like an idiot. Richardson is a great guy and i met two 

women who work for him...also very coot. Yesterday, Richardson called me at 

work and told me they were going to offer me a position..they didnt ’ know 

what yet, and they wanted to talk with me fixther. The problem is, I dont ’

really wnat to work there (issue wise or location wise) Ive ’ already had 

the experience of working in a yucky building. It was ewful. actually, 

because i feel a little trapped into taking it. HOPEFULLY, there will be 

some movement on the other tracks in NY too. I told mr. bacon I was 

planning to move and was in the process of looldng...which is why i asked 

him if i could switch trips with tom. The biggest reason i need to do that 

was because the creeps ’ friend who is supposed to help me with the private 

sector possibilities has been out of town the lest two weeks. I feel like 

111 ’ lose momentum with them if i disappear for three weeks now (thats ’

including Thanksgiving). Oy vey! 

- 

Im ’ glad to hear you guys had such a nice weekend. Honestly Cat, it sounds 

like such a wonderful fantasy to me. To be with yourr husband - as part of 

a couple with other couples doing couple-y kinds of things and having fun. 

My Australian boyfriend CALLED me on Friday to let me know his e-mail was 

down., He said it had become habit to e-mail me friday nights and he wanted 

to let me know he couldnt ’ send anything. I know...whens ’ the wedding????? ‘

Just kiddin. ’

i miss you tons and am so sad I wont ’ see you, but maybe well ’ work 

something out soon. When do you guys come to the state&for holiday? and 

for good? 

kisses and hugs 

Monica 

Date: Monday, Novembei 03,1997 7:15PM 

Hi, I sent you a message called quickie ‘ ’ last wk. but it was = 

undeiive~ble for awhile so Im ’ hoping this wit! reach you. Youd ’ think = 

the fn Pentagon could have straightened out email! Anyway, how did = 

your meeting ‘ ’ go last week? 

of the Iraqi nonsense. 

Im ’ seeing the man on tellie atot because = 

than the DOD. 

I #ink that could be a cool job. maybe better = 

I had a long wkend away from home. We went to a friends ’ offices ’ = 

cottage at Lake Kawaguchi. Its Susans ’ offices ’ cottage and she invited = 

us and 2 other couples for the 3day wkend- so 4 couples all together. = 

It was fun- we drank a lot, ate a lot, hiked, walked, lounged. played = 

games etc..1 was about ready to go home Sunday evening but we left Mon. 

morning. I was getting tired of being surrounded by Brtts! Actually = 

one couple is made up of a German woman and a man, Gavin, who is = 

Page 1 

1037-DC-OOOOOO22 -- 

= 
3634 

Canadian/Scottish/American. Anyway, Chris and I had Monday alone in the = 

city because it was a holiday. We went shoppping, had lunch and saw My = 

Best Friends ’ Wedding, It was a thrill to go to the movies and see a = 

current-ish US movte. I really miss going to the movies as pan of a = 

social life. In the US when you dont ’ feel like having a big night you = 

can just have dinner and go to a movie and at least youre ’ out of = 

thehouse, but here its expensive and the movies are crap generally so if = 

you want o be mellow its renting a movie and eating in which gets = 

tiresome. 

Whoa, L have to go to work! Write back and thanks for the fVfs. What = 

did you pick for the psychological ‘ test? ’ iove. Cat 

Page 2 
OIC-302 (Rev. 8-l%%) 

3635 

-lOFFICE OF TKE, INDEPENDENT COUNSEL 

l/28/98 

Date of transcription 

ALLYN SEIDMAN, Senior Vice President, Corporate Communications. 

REVLON was made available for interview by her attorney, CHARLES A. STILLMAS at the 

law firm STILLMAN and FRIEDMAN, 425 Park Avenue. STILLMAN and his associate JOHN 

B. HARRIS were present during the interview. All persons present were advised of the purpose 

of the interview and the official and personal identity of Investigators-and 

SEIDMAN thereafter provided the following information. 

SEIDMAN has been employed in her present position for 1 year and has been 

with REVLON for 9 years. 

SEIDMAN recalls that on January 8, I998 she received a telephone call from 

JAYMIE DURNAN, Senior Vice President for MacANDREWS & FORBES HOLDINGS, INC. 

(MFH) asking if she would interview a MONICA LEWINSKY whose resume had already been 

sent over to her. DURNAN asked if SEIDMAN would see if she could find a place for 

LEWINSKY. SEID~N did not take DU~AN’S request as an order to hire LEWINSKY. 

SEIDMAN does not remember exactly how or who contacted LEWINSKY but 

she came to her office the following day January 9, 1998 at 11:3&m and was interviewed by 

SEIDMAN. SEIDMAN remembers concluding after the interview that she was a bright. 

articulate and polished person with interesting ideas and would be an asset to the department at a 

junior level. SEIDMAN had seen LEWINSKY’s resume and the cover letter to RICHARD 

HALPERIN and during the interview she chose to concentrate on LEWINSKY’S public affairs 

work experience at the Pentagon as well as insuring that she was aware of what REVLON was 

all about. The interview lasted approximately 30 to 45 minutes. 

SEIDMAN knows VERNON JORDAN and that he is a director on the 

company‘s board of directors. The fact that LEWINSKY was recommended by JORDAN would 

only serve to get LEWINSKY in the door for the first interview, however, his re~o~endation 

’ would have no bearing on the final decision to either hire or not hire her. 

SEIDMAN stated that following the interview she accompanied LEWINSKY to 

NANCY RISDON’S office so that she could make an evaluation of her potential and then to 

JENNA SHELDON’s office, (Manager, Human Resources) for interview and completion of a 

REVLON employment application. 

Investigatton on l/26/98 at New York City, NY Fi,e# 29D-LR-35063 

CI - 

by CI #-k JWB:jwb Date dictated l/28/98 
3636 . 

Allyn Seidman l/26/98 2 

Continuation of OIC-302 of 

SEIDMAN then returned to her office and returned D&&IAN’s call. SElD*~~N 

told him that it was her opinion that LEWINSKY would make a great employee. 

SEIDMAN later learned that SHELDON was very impressed with LEWINSKY 

and was considering her as a Public Relations Administrator helping to pull materials together 

for presentations. SEIDMAN then told SHELDON to begin the hiring process. 

A day or two later, SEIDMAN called LEWINSKY at the New York telephone 

number and informed her that she would be an asset to the department and that possibly an 

agreement could be reached. There was a discussion about salary and LEWINSKY offered that 

she would like to be paid $65,000 per anrmm to which SEIDMAN indicated that that issue would 

have to be evaluated and a decision made. SEIDMAN relayed this information to SHELDON 

and SEIDMAN did not talk to LEWINSKY again. SEIDMAN, of course, did hear later from 

SHELDON that LEWINSKY had been hired and that she would start on January 26,1998. 

SEIDMAN recalls that just prior to all the allegations concerning LEWTNSKY and President 

CLINTON appeared in the news, she made an anoucement to all of her department that “we have 

hired MONICA LEWINSKY on a recommendation from 62nd Street, but she’s great”. After 

reading the press coverage SEIDMAN knew that LEWINSKY would not be hired. 

Kame: 

Sex: 

Race: 

DOB: 

SSAN: 

Residence: 

Telephone: 

SEIDMAN is described as follows from observation and interview. 

ALLYN SEIDMAN 

Female 

Caucasian 

513 150 

EmploymentREvLON 

625 Madison Ave. 

New York City, NY 10022 

Telephone: 2 12-527-6032 

Title: Senior Vice President, Corporate Communications 
3637 

Allyn Seidman, 4123198 

OIC Deposition 

Page 1 to Page 54 

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 
3638 

R5A Allyn Seidman, 4l23B8 -WV 

Page 1 

IN RE: GRAC JURY INVESTIGATION 

151 

-------___----______x 

[61 

[71 

DEPOS:TION of ALLYN SEICMAN, held at the 

[iiofflces of t4essrs. Stlllman, Frie&nan & Shau, 425 

[lo]Park Avenue, New York, New York 10022, on 

[l?]Phursday. April 23, 1998, cumnenc~nq at (10:20) 

'12'o'clock a.m. before Annette Forbes a Certif$ed 

113 Shorthand (Sfenotype) Reporter and kotary Pubxc 

,~~jwithln and for the State of New York. 

Page 4 

i:: 

;:: have before the grand jury that are extremely 

: 3~ Important. because I realue I just used the word 

;;i~~~~~~u;h means -let me explain 

-& I think your attorney probably 

176jexplained. we are doing this here In your 

[ 8 I attqme 

r 

s ‘ Office in order to make life a little 

rsleasler or you and the people that you work with, 

I I o I so you don1 have to physically go down before the 

I 1; lgtmd jury in Washin on. 

IiZ? Do you un 2 rstand that? 

[i3: A Yes. 

[14: Q Our intention is lo mimic as best we 

[ 15! can what would happen in front of a grand jury. 

[I61 A Okay. 

111 ’ Q Our intention is to at some point 

I 18 I read to the grand jury a transcnpt of your 

ri91tesbmony today. 

1201 Do you understand that? 

I21? A Yes. 

1221 Q What we are going to do is make sure 

r23lall the .rules that normall 

[24igfand jury will a p 

apply in front of a 

A &cpkin 111. 

tot Is proceeding. 

1251 

Page 2 

I~~APPEARANcEs: 

13: OFFICE OF THE INDEPENDENT COUNSEL 

1001 Penns lvania Avenue, N.W. 

[4l Suite 498 No h 

Washington, D. % . 20004 

Is1 BY: THOMAS H. BIENERT JR. ESQ. 

l6! STEPHEN BINl-&=EgQ. 

Associate lnde n ent ’ C&sel 

t;; Associate lndehndent Counsel 

[9: [IOj 

,. . . 

Page 3 

[z!ALLYN SEIDMAN,calledasawitness. 

[3; having been first dul 

;:; 

Forbes, a Notary Pu z. 

sworn by Annette 

IIC of the State of New 

York, was examined and testified as 

follows: 

i76jExAMlNATl0~ 

181 BY MR. BIENERT: 

0 M nameisTom Biinert. Thisis 

[:ijSteve Binhak. WY e are Associate Independent 

[I 1 I Counsel and we have not yet had a chance to talk; 

112 1 is that correct? 

r131 A correct. 

[14! Q Let me go over a few ground rules 

115 Iwith you first, just to make sure we understand 

[ 16 1 how we are proceeding today. 

[I?: As you can see, we have a court 

[ 18 1 reporter who IS taking everything down. 

What 

iiiitaking eve 

I would ask is since she is 

y. hing down, we by to make sure you 

[z 11 answer au ably wtih words instead of estures. _) Secondly that we try not to 

! I; i over one aplnoth;;sykay? 

Ia lk 

[24; 

[25j 0 Let me go over a few rights that you 

Page 5 

111 

I21 0 Yes, I will. 

I31 The first thing that it means is 

I 4 ! are entitled to be represented by counse 7 

ou 

. 

151 Do you understand that? 

I61 A I do. 

0 And of course you have Mr. 

ti i Stillman re resent&g you hen& correct? 

!91 1 Right. 

Ilo: Q One difference between a grand jury 

[ 1: ~experience. which is what we are simulating 

[ 12 ! and a normal type of court deposition is 

today, 

x 

our 

I 13 I attorney is not actually entitled to be in t e 

I 14 I room wdh vou. 

i15: bo you understand that? 

I16? A I do. 

i :i i building. 

Q Ofcourse heishereinthe 

You are entitled to leave the room at 

[ 19: any time that you want to consult with him and 

I 2 o I then come back in and answer additional questions. 

(2:: Do you understand that? 

122; A Yes. 

123: 0 That would explain why Mr. Stillman 

124 jis not sittin in here with 

(25: 8 r 

ou. 

o you unders and that? 

- 

Page 6 

[II 

I2i A Yes. 

0 The second difference is in a 

[ii deposition that is a true de ositiin 

I 5: normally get a copy of the P 

you would 

ranscr&. you would 

I 61 be allowed to read it, make cha 

Do you understand tha “9”. ? 

and sign it. 

r7: 

IB? A I understand that., 

Q 

i i : 1 an extremely important obligation to ell 

The other rules that appy you have 

he 

[i6:truth. because this is a duly impaneled grand jury 

[ 17 1 for whom we are obtaining this testimon . 

[la! Because you were placed un c! er oath, 

I I 9 ! anything you say here is subject to a penalty of 

r201P=lury. 

[211 Do you understand that perjury is 

I 22: the knowingly making of a false statement in 

(23 I response to a uestion? 

[241 A ? understand. 

ES1 Q You understand that it would not 

olcstarr Page I to Page 6 
3639 

Allyn Seidman, 4!23/98 UrurV 

Page 7 

11: 

[Z 1 only indude tellin 

! 3 1 aformation, but 

us affirmatively incorrect 

a B so, for example, saying you 

I 4 I dont ’ know the answer to sornethrng or YOU dont ’

isjrecall when, in fact, you do? 

A I understand. 

You also have a Fiih Amendment 

i :: i right not to incriminate yours&. 

!:76iAmendment a lows ra that 

Do you underssti ,what the Fifth 

ou can refuse to answer 

; ; ; ; ~~gj~~~~~~~~~i~,pl,bi~~ b&eve it might 

1201 You understand that? 

(211 A I do. 

Q Any questions about your Fiih 

!I:&endment riohts? .--, 

[241 

1251 

A -No. 

Q I think I have covered all of our 

Page 10 

[li 

A 

ii;New York, 

There are dozens of departments in 

but I - you know what, can 

[ 4 1 to you about that. just so you have spe 

$e$ck 

[51 Q Sure. Thats ’ fine. 

l6i 

['I ~Owl?~ ge x 

ople are in our section? 

epartment I ave 15people 

iii Lewinsk 

Q When did you first hear of Monica 

or the person that you later learned was 

I :,” i Monica %?%eve it was December 8th of 

[1.?]97. ‘

[I31 Q And tell us about what happened 

[ 14 I around December 8th of 97. ‘

I151 

(161 

Aa lF~ed a phonecall. 

1221- A Itis 

Q Did Mr. Duman indicate in that call 

$:lthat ’ he had already met with Ms. Lewinsky? 

I251 A May I speak for a second, can I just 

Page 8 

111 

: 2 1 ground rules. 

[31 MR. BIENERT: Have I missed 

[41 

151 

anfi~~,~Mhak& 

I61 A 

Q 

May I get some water? 

171 Yes. you ma 

Obviously, if you K ave any questions 

[iiabout anything that I am sayi 

[lolconfusin 

[ 111 feel free 9, o stop me and get a da 

whrch has certainly ap ned before, 

“9; iff questron rs 

cation. 

r:rlokay? 

Cl31 A I will. 

I141 0 Tell us what your dutiis are. 

[15! A I am in charge of Corporate 

[ 16 1 Communications for Revlon, Inc. That includes 

[ I 7 1 public relations and corporate affairs for the 

[ I 8 1 company worldwide. 

(19i 0 What is the hierarchy of Revlon? 

ii: idoes 

Who is the head of Revlon and where 

your section sort of fit into it? 

(221 A Ronald Perelman is the executive, is 

(23ichainan of the executive office. Jerry Levin is 

[ 24 1 the chairman. 

! I! 5 1 CEO. 

George Fellows IS the president and 

And I work for George. 

Ill 

Page 11 

r21check with Charlie? 

I31 

Iii 

Q Absotuteiy. 

(Witness temporarily leaves 

;:;A L L YhN’ ” ?%. 1 D MA N. resumed and testified 

(71 further as follows: 

181 BY MR. BIENERT: 

I91 Q Just for the record, you went out of 

I IO I the room for approximately two minutes and 

[ ii I consulted with our attorney. correct? 

[121 A {es. 

Q 

~::~tobgureoutwhatthe ateaandastowhether 

Now, y question was we are trying 

[ls~or not you would have talked to Mr. Duman in 

[ 16 IDecember 8. 97 ‘ or more like Janua 8th of 98. ‘

Cl71 A It could have been ert 3er, and I 

Page 9 

::j 

Q Are the main corporate headquarters 

t: i here in New York? 

[4i A Yes, they are. 

i z 1 of, what 

Q 

is 

You mentioned that you are the head 

the name of the section? 

I71 A Corporate Communications. 

IIi there 

Q 

here 

How many different sections are 

in the New York office? 

LlOl A 

[II ~question. 

Im ’ sorry. I dent understand your 

Q Corporate Communications is one 

i ::;department or section. correct7 

I141 A Right. 

1151 Q How many different sections are 

[ isjthere that make up the corporate headquarters in 

il71New York? 

A There are a varie 

i :“91 units and service departments. 

[ 20 1 you with the specifics. 

[zllsor 

r 

- Revlon Consumer Products U.S. There is 

(221 Rev on Professional. But - 

1-31 Q Im ’ just trying to get a ballpark. 

1241 Are we talking five or six 

[ 2 5 1 departments? Are there dozens of departments? 

Page 12 

I:Iher. to see if she was right for the organization, 

161our organization. 

Q Now. Mr. Duman is in technicalty 

i;iMatindre~ “y,’“,, “‘ right? 

I91 

I101 Q -You are, of course. Revlon? 

Cl11 A Yes. 

Q 

i::ihad spoken himself with that can rdate? 

I ::beliive 

A 

Did he indicate top whethe: 

I don’t remember exactly but. 

he saw her because he told me that 

s, I 

[i61thought she was g&d. Thought - it may have been 

r~7limplred. 

Q 

i:i;with Mr. Duman, was it on the same day 

Was the conversation thatgpd 

[zolappeared that he had spoken with the candidate, 

I z I I the da2 after or a long time after, or do you 

rzlknow. 

I231 A I dont ’ know. 

/:;;you took? 

Q What was the next step, if any, that 

Page 7 to Page 12 OlCStan 
3640 

asA 

Page 13 

11 

(21 A I scheduled the time, and if I 

; : ; t~~~~l~ :: ~~~h~~~~~~~~ 

[ 5 I scheduled the time for Ms. Lewinsky to coma in. 

$1 

Q When you say the next day, I assume 

ou mean the day after you would have spoken to 

[a] t r. Duman - 

191 A Yes. 

101 

ii; jracord. 

Q Let me finish mv _ auestion . for the 

I am assuming that you mean the day 

i::;after you would have spoken to Mr. Duman about 

[ I 4 1 Ms. Lemnsky? 

il51 A Yes. 

Q 

!:76191h. whichever month we are talkino about? 

So roughly December 9th or January 

,- 1-- I 

1181 A Yes. 

I191 0 Is that correct? 

1201 A Correct. 

0 Did you then, in fact, meet with Ms. 

i::iLewinsky on the 9th whichever month it was? 

[231 A Yes, 1 did. 

(241 Q Who was present when you met her? 

I251 A Nobody. 

Page 14 

[ll 

i:;her. 

Q Tell us about your interview with 

What I would ask you to do is tell 

i li us in as much detail as ou 

I 61 that you talked about Tl 

can about the topics 

w at was said, et cetera. 

A I took her through our department 

Ii jthe Corporate Communications Department, and’ the 

[ SI 1 way that its set up. 

(101 I asked her what her interests were. 

1111 

I121 Bid &! ~~~~~~~~~~n~d. 

:l~rwithyou.seemtohaveavetyfc$dde geof 

: I 4 Iwhat L was that you and the o 

;~s~department did? 

A She was familiar with public 

itt;relations and corporate communications, since she 

r 18 ] had worked in that area. it was my impression 

’ 1.91 that that was the reason, because she had worked 

iz o 1 in that area in the Pentagon. 

0 

i%ideoartment did 

So ou explained to her what your 

an Cy- .--1 , 

1231 

i241 

:251 

A Right. 

Q And what else? 

A I showed her the different areas 

Page $5 

ii ‘ 1 where we had a need for help, and talked to her 

r . 3 i . about which she preferred. 

0 Which areas did you indicate to her 

i : 1 that you had a need for hel in? 

A The corpora!a affairs area and in 

![ tithe ma~eting public relations area. 

Is it accurate that at the time that 

i iii more specific? Because there were 

rzolopenings then. 

There were - Im ’ so~.~ you be 

i2ll Q 

A 

What were those two jobs? 

One was working as a 

iii i relations assistant to the Revlon and R 

ublic 

lmay 

[ ;I 4 I business, and one was working as my executive 

12 5 1 assistant. 

-.- 

OICSWS 

Allyn Seidman, 4/23/98 

Page 16 

uuol 

There was also a naed in two other 

i5iareas of the de arm-rent. 

i4! Q &at were those two areas? 

IS! A 

i 6 1 marketing 

Corporate affairs and in the 

8 

ublic relabons area. 

Can you explain to us, what is the 

iii distinction between an opening” ‘ and a “need”? 

A The two specific openings that I was 

i:i!discussing had been - there were people in the 

( 1 I 1 jobs before who had just left. 

Q 

;::;right? 

Those are the openings; is that 

1141 A Yes. 

1151 Q What did you mean when you said 

[16]then9 was a need? 

[I71 A Weneededhelpintheothertwo 

miareas. 

Does that mean there was never 

You gave me a title, I think, but 

Page 17 

I11 

IZ iust ’ to go over it a 

c, 

ain, what would the two areas 

131 avebeenwhere &e rewasaneed? 

A Corporate affairs and marketing 

i:jpublic relations areas. Product publicity. 

Q I think a few moments ago ou 

I ,” ; indicated to us that you explained to her vJat 

[ 8 1 your department was and what it did and then you 

[ 9 1 asked her about which she preferred. 

Iiilthat? 

Can you explain what you mean by 

A 

I::ithe candidate. I do tha qude often in 

It was rnr way of getting a feel for 

~l4;interviews. 

1151 Q Elaborate on mat. 

What did you say to her, what was 

i :7” i her question? 

;:;jwould fit. 

A Where she thought her experience 

!:fibut it is a common tichnique that I use when I’ 

You know I dont ’ remember exactly 

:zz?talk to peo le. I sa 

[z3ifeel about !l x 

to them, tell me how you 

at, to nd out if they understand 

(24 idifferent areas of the business as well. 

[251 I was on a tight schedule and I 

III 

Page 18 

~2 I wanted to see how deeply I could 

[3: 2 

i : i the candidate. 

Ty;atd; 

Q When you say you were on a tqht 

j76jschedule and you.wanted to detemrine how deeply 

I 8 I ou wanted to go Into each area, am I accurate, do 

[91 r take tt from that what you were doing, you were 

[lolthrowin 

f 11 I she 59, d 

out to her avarlabiliis in an area, if 

she was not ,interested in it, you 

;;:;wouldn t bother explarnrn~$? 

A I was wat ing her reactii to see 

[ 14 )if there was a ftt for the can&date in a variaty 

rlslof areas. 

It is a technique that I use when 

;:761lrn ’ interviewin 

i :i ~ talk to 

Q 

her 

gt!%%&y different areas dii you 

about to watch for her reaction? 

~:~~relations _Aor ~~~~~~~~.m~~~t~.public 

Theres ’ a vanety of d erent 

i::ititles for the area. I dont ’ remember I dont ’

[ 2 4 1 recall if I was specific about m exe&utrve 

[ 2s ] assistant job, because I knew r needed diierent 

Page13to Paga 18 
3641 

By Allyn Beidman, 4/23/88 

. . 

.-. 

Page 19 

::. skills than a public relations admrnlstrator 

: 2 : assistant. 

c4: Q You know you went over with her the 

: 5 comorate ‘ affairs position, riqht? 

:- .6: A Y&.. - 7‘ ‘ 

. . Q That w;s one of the positions where 

iSjMerrwas~no~~~~;ledsomebodythere. 

1C: Q But thats ’ one of the need” areas 

11: and not the open area? 

.-. 

i;jaffaim 

A We needed somebody in corporate 

14: 0 Let me repeat my question. 

15: Was that one of the areas where you 

: 6 : were saying there was an opening you were trying 

: 7 : to fill it or was that one of the areas where 

:; : there was a need but there had been no person 

;19:y1 rorking? 

r25‘ A .--. There was a need. 

Ifi i no openin 

Q By that, do you mean there had been 

% Yes. 

for that position? 

123: 

124: Q Corporate affairs was a “need” area. 

i25: Marketing and public relations, was 

. . 

.-. 

Page 20 

i 2 : that One Of the sections - 

li- ,-_ 

!4: 

8 ~$=tJg.g.d - 

,i. Was that one of the areas where 

1 i: there was an opening where you were trying to fill 

: - : or one of the areas where vou fett there was a 

i?ineed? 

:4: A Both. There was an o 

; I:: there was also - there was an area t R” 

ning and 

at had been 

.:: .staffed bv interns and thev were teavina. Im ’

i I: i sorry. I just remembered that. - 

.. i‘ Q 

i :: f particular s 

So was it accurate then there was a 

: rs:relations w t! 

ot within marketing and public 

ere there was an opening, but separate 

: ; E: and apart from you thought there might be a need 

:;-:for a new osition. 

..=. ,A-. !vh at was the difference? 

/. j. 

iI: i and 

Lets ’ talk first about the marketing 

public 

::r:opening. 

relations position where there was an 

,__. 

,--. 4 Excuse me. When I say marketing 

: 13: public relattons, its marketin 19 .I public relatrons, 

:z:. rts ’ product publicity, its pub emng. rt s 

: 2 5 : supportrng marketmg. It s not a marketing job. 

Page 21 

.-. 

r-. 

L-. Its ’ marketing PR. its ’ not 

:?.marketing and public relations. I wanted to be 

r::dear. 

IC. 

,-_ . Q ,, So far we have covered one of the 

[ 6 : openings was In marketing public relations. 

r-. Then you felt se 

f 3 i from that there was a n eed9 

arate and apart 

for a new position in 

r 9: marketina public relations; is that correct? :im. “. -A Onewas- 

. . . 

.--. Q Is that yes? .,_I, 

.--_ A Yes. 

113‘ 0 There was a corporate affairs area 

!I, iwhere there was no opening, but you thought there 

::5:could be a need? 

;!E; A Yes. I knew there was a need. 

..~. Q And what was the other position 

i I? iwhere there was an opening? 

::3: A M assistant. 

:2:: Q Tf?at would be the executive 

::. ‘ assistant position? :__: 

_-- .A Yes. 

.-u. Q Were there any other openings or 

: :: : “need” areas that you believed were potentially in 

::s:play when you met with Monica Lewinsky? 

Page 22 

[II 

A I dont ’ recall. We always had a 

1; 1 need for administrative positions in the 

[ 4 i department. 

I z 1 

0 As you rnterviewed Ms. Lewinsky did 

~71 &I 

ou detemMe whether or not she was appropriate 

r edher of the two opening areas, the,marketing 

18 lpublic relations opening or your execubve 

I 3 I assistant ooenina? 

IiOi A Yis. 

1111 Q 

I121 A 

What did you determine? 

I determined that she was not 

I 131approoriate for either oosition. 

1141 Q Lets ’ focus first on the marketmg 

[ 15 1 public relations opening position. 

i :7” i not appropiia e for hat position? 

Wh{ did you determine that she was 

A Because we were looking for somebody 

I:i;who had a Btle more experience in beauty fashion 

(zolthan Ms. Lewinsky had. 

Q Now, when you decided that she was 

1:: i not appropriate for the executive assistant 

[29]positton. why did you make that conclusion? 

1241 A 1 was lookin 

[ 2 5 1 corporate, more in 

for more experience in 

corpora P e executive assistant 

Page 23 

I11 

12 1 skills, with corporate executive assistant skills. 

Q As to either of those 

I:lthen. in essence, you concluded tha P 

ositions 

she did not- 

(5 J have enou h experience to fill those slots? 

I61 1 Right. 

Q By the wa 

tilwith Ms. Lewinsky these X& 

when you went through 

o possrbte areas, did 

c91you - 

A 

i : F 1 soecific or not. 

Im ’ trying to remember if I was 

I reallv dont ’ recall if I was 

i ijjvbry specific about those areas. 

I::; her through, you mean orally, not physical y 

Yes, maam. ’ When you sayqou took 

I211 A Right. 

I dont ’ remember if she specifically 

i:: 1 said anythin , but I do remember that she looked 

124 lea er when 

rzslof Wings. B/t thats,.. ’

talked about the beauty fashion end 

Page 24 

[II 

0 

I-5 i public relations 

And that wouM be the marketing 

[41 A ~:rton? ’

[51 Q So whether it was throu 

I 6 1 nuance or expression, you conduded t !! 

h words, 

at that was 

17 J an area that she was Interested in, correct? 

I81 A One area, yes. 

Q What other areas did you conclude 

r:zithat she was interested in? 

A I concluded that she was interested 

i ::; in perhaps kamin 

[13jpress, which cou k! 

more about working with the 

be - 

1141 0 Which could be what? 

A Any number of, it could be either of 

!:zithe areas that we just discussed. 

1171 Q So we have covered in the interview 

[ 18 I that ou 

I 191wha ty d was and what it did, 

spoke with her about your department, 

r2o jabout kind of work areas, 

ou did some talking 

w I! 

12 11 or specific. 

ether it was general 

(221 What else did you discuss with hefl 

A 

1:: 1 Idiscussed the culture of the compan 

Im ’ sorry. I am trying to r;ymber. 

[zsirecalt correctly, I believe I discussed t K at, that 

-. ____ 

Page 19 to Page 24 

_~_ - 

otc-stan 
3642 

Bsh Allyn Seidman, 4/23/68 XMx(6) -..- ---- --- 

Page 25 

;i J it was fast paced. that the hours were long. 

1 told her that I liked her Pentagon 

i: jexpertence. because many times the departments 

f 5 Iwere subject to confidential information. I dont ‘

[ 6 1 really fecellQ exac$+.E~ut that s... 

171 isi A Thats,it. ’

Q When you set up the interview, I 

[ :iiberieve ou totd me ou had first heard about her 

L 111 the day Ire f~zxeY% X4 r. Duman; is that correct? 

ii21 

Q VIlho would have actually set up the 

I :: jinterview. you. your secretary or Mr. Duman? How 

: I 5 I was that handled? 

A I believe that Mr. Duman set it up 

li76lfor me. I ave bun a time. 

!191 %l But you gave him a time for the next 

ilgiday? 

I201 - A Yes. 

/Z: iset up so 

Q 

uick 

Why was it that the interview was 

7 Was there any reason for that? 

1231 I ?mmyperspecbve treceiveda 

t 24 1 hone call from Mac4ndrews 8 Forbes, which is our 

[ ~5 1 c oMrng company. I respond quickly to them. 

- 

Page 26 

ill 

ii1 Q why? 

131 A They are our holding company. 

[41 Q So what? 

A The are the maj,ority shareholder. 

/a / I respond gulckk$espond quickly to them. 

141 A I work for them. 

Q Is it accurate, maam. ’ that when you 

I i z i get a call from the holdi 

: I 1 i essence the bosses., tha r? s something that you know 

company, which is in 

; i 2 1 you have 2 pa)r$az;czr attenbon to? 

::3j 

:141 Q And thats ’ the reason why YOU made 

i : 5 j sure that t? inte$~.m~as ‘ set up quickly? 

iFi ‘.--+ 

Q And that was based on a phone call 

iii 1 that you got from Jaymie Duman, who 

:: 9 jconsrdered to be a superior at least in 

ou 

:_ D T hierarchy of the comoanies? 

r he 

:_,: t--i -A Yes: 

1-1: Q Did Mr. Duman indicate to you that 

i 5; 1 anyone else had spoken to Monica Lewinsky before 

: 2~: he - other than hwn? 

.1F1 

.--. A No. not that I recall. 

Page 27 

,*. 

:2: Q Did he indicate to you that he had 

: 3 IS 

E 

oken to anyone else within MacAndrews or Revlon 

: 4 ! a out Monica Lewrnsky? 

cl ‘

i;! 

A Not that I recall, no. 

Q Do VP” have any knowledge as to 

: 7 Iwhether or not Mr. eretman spoke wrth anyone 

: 9 jeither on the MacAndrews 8 Forbes side or the 

islfievlon sidt abg$ Monica Lewrnsky? 

i:31 

i 11 i employee 

Q Now, she was an entry level 

correct? 

I131 A ‘ Yes. 

[I41 Q Did ou know that before you sat 

r:s]down with her or rs &, at something you just 

; 16 1 teamed once you sat down with her? 

.s_) A I knew that when I saw her resume, 

; : 3 1 but it was reinforced when I sat down with her. 

Q 

ii,’ i of your interview wrth Ms. Lewinsky? 

How ; you leave t~~~~~ end 

1:: 1 anything, zti y~;~g to her? 

I_/“, r I would like her to talk 

isi{to Nancy Risdon, who is vice president of 

[ 2 4 ]Co orate Affairs. and that I would then take her 

izslto Fp uman Resources to meet with them. 

Bic-starr 

Page 28 

.f. .^ 

.-. Q 

:j:bme. 

Lets ’ take them each a step at a 

Nancy Risdon was vtce president of 

ii :Corporate Affiirs. 

16: Is that a separate department? 

.-. 

;,: 

A She works for me. 

Q Thats ’ under Corporate 

f i ~Communications? 

iZ1: Q Dii you s 

;ZZlshe spoke to MS. R” 

ak to Ms. Rion after 

Lewrns y? 

:73; A Yes. _ 

124: Q Did Ms. Risdon indicate to you 

r;iswhether she believed Monica Lewinsky wouM be 

Page 29 

i-j 

721 rioht for the needs she had? 

I3j - A Nancy indicated to me she thought 

I 4 phe was talented and would be right for the 

rsideoartment. but that her. she was not exoerienced 

i6 ienbugh for what Nancy was lookrng for at ’ that 

I 7 j point in time. 

!3l Q Now, when you to@ Ms. Lewinsky that 

! 4 !she thouki meet with, I think you said the Human 

r 20 ! Resources personnel. what function does Human 

i : i : Resources serve at the offiat? 

g2; A Human Resources helps me evaluate a 

: 13 ~candiiate, whether or not she is right for the 

: 14 I corporation. It 

I use 9 

ives me another opinion. 

hem for that quite often and 

I t z j they help evaluate as we go forward 

*P 

ay scale and 

::7jco 

IR” 

rate policy. They do that, its ’ he p as 

:la!we 

1:9: Q Is Human Resources more or less 

; 2 -J :involved in the hiring of, for exampbe. entry 

~2:. I level employees than people who are coming in at a 

:z 2 : more senior tevel? 

:23: A I use them for both. 

r2.I: Q So from 

i 1s I involvement of Human J 

our perspective. the 

esources in the hiring 

Page 30 

iI1 

iz ~process is no greater or krss, whether its ’ an 

: 3 I entry level person or a senior level person? 

i:i 

isi 

A Right. Right. 

Q You are hesitating. Is there more 

ii:to add? 

A Occasionally I will have them - 

I i j no, thats ’ correct. Thats ’ cobct tm ’ sony. 

!9j Q Is it accurate, maam. ’ that at least 

I IO with entry level pea te the 

I 11 iinterview with the 

woutd normally 

[IZ J before interviewin&h ye!!?? 

uman esources Department 

[I31 A Dfcourse,itis. 

;::;case thou 

Q 

h? 

That wasnt ’ what happened in this 

% No, because I had received a phone 

~:76~call from MacAndrews 

119: Q 

i19j 

Ma&brews 8 Forbes? 

A And Forbes. 

123; Q 

I 2 1 !wouU be goin 

When you told Ms. Lewinsky that she 

IX! Resources, iFI 

to meet with people at Human 

w at exactly did you tell her, as best 

:zj:you recall? 

- . 

A I dont ’ recall. I just tokt her 

f:: i that it was part of the process. I dont ’ remember 

P8ge 25 to Page 30 
3643 

esA Allyn Seidman, 4125138 

Page 31 

_-. 

I@: A No. 

Q Have y& ever had a communication 

I: zivia letter or other form with Mr. Jordan? 

iilj A No. 

:.-,: Q W you know, prior to intefview+ng 

; ‘ l;; Ms. Lewinskv. that she had any kind of connection 

F. 4 i to Mr. Jordari? 

;I:! A Onty becXiUSe there was a letter 

r I E I attached to her resume when Javmia sent it on ,_.,~ 

:;71over. 

IlPj Q Acoverlettefl 

(191 A Yes. a cover letter. 

Q That woukl have been a letter from 

I zz ; Ms. Lewiniky t;_Tne at Ma~ndr~ or Revlon? 

(22: 

Q Isnt ’ it a letter in which Ms. 

1:: j Lewinsky referenced the fact that she was refened 

12 5 2 by Vernon Jordan? 

Page 32 

1:: 

:r! A Yes. I believeso. 

Q You know Vernon Jordan to be a 

! : 1 member of the board of directors of Revlon? 

:5; A Yes 

16: Q You would have known that at the 

;-.timeT 

It’ A Sure. 

Q Did 

; ! 4 i Vernon Jordan at 

ou speak to Ms. Lewinsky about 

a r I? 

II- ‘ A 

ifS;recall. 

Not that I recall. Not that I 

I.3: I was interested in her Pentagon 

[ : : : experience and communications was my focus. ..i Q DKI Ms. Lewinsky mention anything 

; ;z i about the White House or her experiences there? 

,._. .I A Not that I recall. 

,.z. I dont ’ remember exact1 

;I j;was. I was really focused on whet z 

bui it 

er this woman 

; r~ 3. would fit into the department and where she coutd 

!:::beafit,ifshewasafit. 

;2:: Q Did Ms. Lewinsky tell you anything 

[: 5: about an other jobs that she was interviewing for 

::;::or cons1 -c! enng? 

t-5: A I dont ’ remember. It% - I dont ‘

Page 33 

’ : I 3 remember. Its ’ hard to remember if I read 

i 5 : the press or if we dtspussed it in the office. 

it in 

Q Are you aware though, as you sit 

if i here now, that there were other jobs or names of 

t 6 : people who she was speaking with or had an 

: - : tnterwew with? 

I$’ A I am aware that she spoke to Busson 

: s 1 Marstellar. and I am aware she spoke to American 

i i :: : Express. 

Q As you sit here now, you are not 

iii i sure she would have referenced any of those; is 

1; 3 j that correct? 

[14: A I dont ’ recall. 

[iSI 

(16: 

AQ lS$5$f&&~lf”m the press? 

Q At the time you concluded your 

i i j interview with Ms. Lewinsky. but prior to sendin 

113: her over to Human Resources, had you condu 8 ed In 

[ 2 c : your own mind whether you thought she would be a 

[L: I: good hire or whether she would not? 

I?:: A She was a talented, enthusiastic, 

[ 2 3. bri ht youn woman who was very eager. I liked 

[24:th8 in my r%partment. 

125: Q So whats ’ the answer to my question? 

Page 31 to Page 36 

Page 34 

,. , L-. 

i-: A Yes The answer to the question IS 

{;]I had not concluded - well. I had concluded that 

[4;she would ba a good fit m the department. 

Q Is d a-rate ma am that at the 

jZiconclusion of your mterwew: your rnient was that 

ijshe ’ be hired? 

[?! A Yes. 

!91 0 Now. when you took - 

iI01 A Contimjent ‘ on Jennas ’ opinion. And 

i :I 1 contingent on Nancys ’ opmion. 

ilZ1 Q When you took her to Human 

[l31Resounzes, who did you turn her over to? 

114; A Jenna Sheldon. 

Q 

[Zithe intefflew? 

Did you then absent yourself from 

1171 A Yes. 

Q What, if anything. would ba the next 

I : z i information or *tact or anything you had related 

;;;;to Monfca Lemy? 

A I be teye I spoke to Nancy first, 

122 ~who toki me that Monica was very impressive. I 

123 1 toM you that. 

Jenna called ma and told me she was 

i::]vefy impressed, and Im ’ sorry if I dont ’ recall 

[II 

Page 35 

rzithe exact order. I know I had these phone calls. 

[ 3 1 Idont ’ remember what ti exact order is. 

/ :i him I thou 

And I know I called Jaymie and told 

ht she was great. 

161 

17,indi~ted~ats~d~~n~~~:ko~~~~~she ‘

[B 1 openmq under her that Ms. Lewmsky coukl fit, 

[slconect. 

Yes. She felt that she woukt be 

Dii Ms. SheMon indicate to you 

::76iafter she spoke with Ms. Lewinsk whether she 

118 1 believed that Ms. Lewi Twastf!erightfitfor 

r 19lany of the openings that s e was aware of? 

[ZOi A Jenna told me that she thought that 

(21 lshe was, and I dont ’ remember exactly, I know 

122) Jenna indicatfl that she thought she was great and 

II : ?ould be %Zod ~~~o~~~~ny particular 

[ 2 5 f openings with heR 

Page 36 

(11 

A Yes. And. again I dont ’ recall 

j,lexactly ’ how the conversation w&t. but we 

[ 4 ldiscussed that she would be right to start in the 

[s I marketin public rebtions art of the department 

r6landsee!sheworkedout!?ere. 

I think we talked about that in that 

ii jconversation, Im ‘ pretty sure we must have 

[ 9 ldiscussed it at some tune with an administrator 

riolthere. 

Q This would not be the sition for 

I::;which there was an exist@ opening por ” marketing 

I I 3 1 public relations, correct? 

A No. We did need more beauty fashion 

Ii: ;experienca for that. 

Q This wouk! be an area were there 

! i: j wasnt ’ an opening but 

ils~need and someon& cou 

ou felt there woukt ba a 

b ba used, correct? 

i191 A It was a great opwrtunity yes. 

[ZOI Q Great opportune for her? 

A For us. 

olcstam 
3644 

By Allyn Seidman, 423138 

Page 37 Page 40 

..! 

:21 A She was a bright young woman and we 

13 1 needed the hel 

0 bat if anything would be the next 

i :i steo that YOU recall in the orooression of the 

I know I interviewed her on a 

:z3jFriday. 

Then I believe I called Monica to 

if; 1 tell her, after I thought, after Jenna and I - 

,I. 

[21she was hoprn 

Q khrs IS back when 

to make when we were mtenvewrng. 

i:jwith her, a;theT;Etvrew on the 91 g 

ou were In person 

? 

15: 

[6: Q Tell us about the discussion about 

11:satary. 

A A ain 

iii but many of the, $ 

I dont ’ remember the details 

know I asked her what she hoped 

[molto make and she told me that she hoped to make 

r:11$65,ooo. 

i :: ;sure of. 

And I believe -thats ’ what Im ’

I believe she told me that she was 

I 14 1 making around 50 or 55 with her overtime, that she 

I 15 lwas currently making 50 or 55 with overhme. 

I161 Q And so what, if anything, did 

[~?]tell her you thou ht ou guys would pay he J 

ou 

I181 A I ioft{ know if I was specific. I 

I 19 Iknow I told her mat was steep. 

0 Any other discussion about - lets ’

I:Fiback up a second. 

What, if any, reaction did Ms. 

I::; Lewinsky have when you told her you thought that 

1241was steep? 

USI A Again, this was a while ago, but I 

Page 38 

:11 

;Z 1 

I 3 1 r

ou know what, I dont ’ remember the exact order. 

know I also spoke to Monica to tell her I 

r 4 1 thought she would be a good tit in the department. 

Q So while you are not exactly sure of 

i z; the order I assume it would have been after you 

7: lsooke to kancv Risdon and Jenna Sheldon. correct? . 

iR1 A Yes. 

Q Is it accurate it would have been 

: i~~either within the same day or within a day or two 

: : 11 after day Ms. Lewinsky had been in the office 

; -; 1 rrrrviewing that you would have called and told 

_--, : - - 

:141 

151 ‘ ’ A0 Yes. - that she would be good for the 

: 6 1 department? 

1171 A Yes. 

1131 Q Why dont ’ you tell us as best you 

.:3 1 can, walk us through that conversation. 

A I told her I thou ht she would be a 

ii? i ood fit in the department, an 

-21 j 9 

8 I told her that 

enna would be calling her. 

::3: That is the way we do things. 

4) Q Did you talk at all with Ms. 

: z 5 1 Lewtnsky about what position you thought she would 

Page 39 

.-_ 

: 2 1 be getting? 

:3! A If I recall correctly,, I believe 

: I 1 that I told her we would start her rn the beauty 

: 5 1 fashion area and that we would start her in the 

:6!beauty fashion area. 

“I Q So other than saying the beau 

_ 3 1 fashion area, did you sa 

Y; 

you are going to be ? he, 

: 91 and give her the name o a position? 

A I dont ’ remember. Its ’ usually 

[_fithats ’ usually, those are usually specifics that 

: : -’ 1 HR works out. 

So its ’

i i: 1 her a title. I don’ P 

ossible that I didnt ’ give 

remember. 

:151 0 Did you discuss salary at all with 

: : 6 1 Ms. Lewinsky in that conversation? ..? A 

f I ; j Again, that is 

I dont ’ think so. I dont ’ recall. 

something Jenna would talk to her 

: : 9 I about. 

Q Did 

!?iMs. ‘ Lewinskv? 

ever speak about with 

:__); 

.--: A _ Yes. 

:I31 Q So how man different conversations? 

::?I A During the in&nriew - Im ’ sorry I 

: 15 1 didn't speak about her salary. I asked her what 

Page 41 

Ill 

[2 Idont ’ think that she was disturbed by it. She 

[slsaid she was moving to New York and she knew it 

I 4 l would be more expensive in New York. 

151 Q Now. lets ’ go to the phone call mat 

[ 6 I you had with her after the Interview. 

%ith her? 

How many phone calls did you have 

OU ‘

;ky? 

Page 42 

,. , 

11: 

I21 A Because thats ’ what thev do for a 

r31kvrng. 

14: 

(51 

I61 Q You said thats ’ what thev do for a 

17 1 living? 

[El A For a livin 

Q Meaning w at Human Resources - 

[ :z; normally deals with the lower level employees? 

I :: 1 normall 

A Meanin that Human Resources 

[ 13 land all r he details of that. 

deals with sa % ry negotiations and offers 

Q Maam. ’ you were interviewed by a 

i::icouple of FBI agents back in January of this year, 

[16lCXNlWt? 

1171 A Correct. iisi Q 

[19lguvs, right? 

And you do recall talking to those 

rzoi- - - A Isuredo. 

1211 Q Is it true, maam. ’ that when you 

1221s e to them 

P r 

ou toM them that when 

[231 r. Duman tha Mr. Duman asked you i! 

ou spoke to 

124 lsee if 

you could 

rzslthe A& 

ou could find a place for Ms. Lewinsky in 

Department? 

-- 

OlCStarr Page 37 to Page 42 
3645 

8% Allyn Seidman, 4123/98 

Page 43 

ilj 

1:; 

i:i 

8 &S,teS,t; ‘ : ‘ tN@. 

A Yes. 

;:; that? 

Q Mr. Duman did, in fact, tell you 

A He said to interview somebod and 

ii ; asked me to see if there was a place. I don’ r 

[ 91 remember the exact quote but, yes, that is 

[10lcofred. 

[ill Q Other than this folm-up phone call 

[ 12 1 that you would have had with Ms. Lewrnsk 

! 13 1 have any further communication with her a r 

did you 

all? 

1141 A I dont ’ think so. 

0 After 

[:~~conversatiins with hx 

our either conversation or 

s. SheMon about what you 

[ 17 1 thought of Ms. Lewinshy, what you thou ht about 

[ 18 1 where she woukf fit, how was It left wrth %I s. 

[ls]SheMon? 

120: A To the best of my recokedin, 

1211Jenna was goin 

(zzloffer letter and t% 

to make her an offar, sent her an 

ecked references as well. 

Q Did you discuss references at all 

i : : i with Ms. Lewinsky when au met with hef? 

[151 A I dont ’ thin x so. 

Page 44 

[II 

Q 

i: {next? What was the next hing that you 

What. if anThing else, hagperted 

amed or 

[ 4 1 heard about Monica Lewinsk 

[ 5 1 understanding was Ms. Shel J 

after your 

16 1 her an offer, et cetera? 

on was going to send 

A 

Ii i recokection. 

Im ’ doing this to the best of my 

I believe that Jenna told me that 

rizishe had accepted and. a ain it was a while ago, 

i 111 but to the best of my reco s lechon, I ‘ I told my 

[ 1-7 1staff we had a new person coming and then I opened 

113 )up the newspaper. 

Q Obviously when you told your staff 

i::jyou had a new person coming, that was prior to the 

i L 6 1 news becomin public - 

I171 “0 &course. 

- about the allegations between her 

i : “, I and the President, correct? 

A 

i: P 1 calls in between and I just don t remember. 

Yes. There may have been some phone 

I 

: : 2 *mean, thats ’ to the best of my recollection, 

;?3jthats ’ what hap ned. 

::4: Cl %one calls with whom? 

:25; A I dont ’ know how many times i talked 

1‘ ’ 

Page 45 

r:!to Jenna. Thats ’ what I am saying. 

[31 Q Meaning about the whole process - 

[41 A Yes. 

[5! Q Let me finish the question. 

161 - about the whole process of 

I ? 1 gettin 

9 

Ms. Lewinsky on board, is that what you 

rsrmean. 

ISI A Yes. 

Q 

1 it i at some point not too long after s emtenrrewed ’

Is it accurate tenth .maam ’ that 

I I_’ 1 you came to an understandin wtth Ms. Sheldon that 

113 ]a ob offer had been made to s. Lewinsky and that 

114 j M’ s. Lewinsky had accepted? 

A To the best of my recollection. And 

i:zi I would love you to check that with Jenna, also. 

! I 7 1 To the best of my recollectron, es. 

I191 Q But you do reca r I telling people in 

[ 19 1 your department - 

1201 A Yes. 

[:I ‘ Q Let me finish the question. 

!?I ‘ You do recall telling the people in 

t23:your department that a new person was going to be 

12 4 1 starting. correct? 

[25! A Yes. 

--_ _.-. 

Page 43 to Page 48 

.- 

Page 46 

Q When YOU said that to vour 

; 3 !depamnent, the new person you were-refemng to 

! 4 ~was Many Lyeyky? 

[Sl 

161 Q You wouklnt ’ have done that unless 

!7 I you knew that an offer had been made and she had 

I 8 I accepted, correct? 

131 A You are absolutely right. 

101 Q Is it also accurate, maam. ’ that at 

1 I ithe time that you toM that to our department. 

:ZI 

131 I ewlnsky? 

ou had in mend a rough sta x ing date for Ms. 

A I believe that would be correct, but 

i:jldon?-yes. I robablydid. 

Q !nd the starting date was not that 

:%rinthefuture correct? 

IlBl A &orrect. 

:191 Q 

rzo,weeks? 

Talking a matter of a couple of 

A You know, I dont ’ remember the exact 

i::idate, but yes. I can 

i23jSut. yes. I would no $ 

t back to you with that. 

have, unless she had 

[241accepted, I wouM not have toid my staff. 

1251 Q And you knew there was a starting 

Page 47 

111 

r z I date mat was cominq UP? 

I!1 A R‘ ht141 Q V%eii you spoke with Ms. Lewinsky, 

: 5 7 did YOU talk with her a all when YOU sooke to her 

: 6 j in p&son about the time issue, when she was 

c 7 I looking to start, how quidtly she could start, 

f 8 1 when you would be looking to use her? 

I91 A I dont ’ remember. Its ’ something 

11 o 1 that I would normally discuss in interviewin 

Q You are assuming you did. 

i 1: ; have no recollection? 

%ut You 

A I cant ’ remember. I real1 

! ::)I dont ’ remember. I probably would, bu Y 

cant. ’

I dont ’

ilslremember. 

Q After this series of conversations 

i if 1 Or whatever it was with Ms. Sheldon and you knew 

[ I B ithat Ms. Lewinsky was going to start you informed 

our department of that, what would be the next 

that happened in the sequence of calls in 

I “‘

onrca Lewinsky setting? 

1 I; 1 Ms ’ sa 

A I don t know where Jennas ’ offer, 

! 24 1 fit into t!i 

fits into this and where the references 

at, but that was, you know. Jenna will 

! 5 ‘ 1 have to fill in the blanks on that, but that was 

Page 48 

I.. ,-, 

r]it. 

2‘ ’ 

;;ithat? We 

What wouM be the next thing after 

I!? 

nned to have Monica Lewinsky come. 

;51 And then what hap ned? 

!6! A And then I receiv ec/?phone call 

[ 7 ~ from somebody in my department. I was at an event 

18 I@ Aspen and I received a phone call from somebody 

[ 9 I m my department. 

::31 Q Who was that? 

A I 1: i ~-is-ci_&~i. Jadzia, J-a-d-&a, Ziilinski. 

1131 Q 

A 

What did Ms. Zilinski say? 

She told me too 

I:: ’ inewspaper. And she read me, p” 

n up the 

I 16 I USA-Today. 

believe she read me 

-- (17: 0 What did she read you; what did she 

f :e i in substance tell you? 

A She basically said this is the woman 

i:iithat we are bringing into our department 

You know I wasnt ’ even focusing 

i~~&ecause I had beenat ’ this retreat in Aspen.’ I 

123 ~Said I will ba homa later. And we - I was on my 

I 2 4 1 way home anyway, so. 

jz5: Q Is rt accurate that what she told 

OIC- Starr 
3646 

BSA Allyn Seidman, 4Q3198 -WI _._ --- ____-- 

!:’ 

Page 49 

;_ :you was. she read you these allegations that 

; 3 :sornethlng was oing on - 

!4‘ 

rsi 

; rft ht. 

I 6: President? 

-?n?tween Ms. Lewinsky and the 

.~. 

ilO: A Yes, she did. 

11:; Q Diisheaa toyouthattherewasa 

[ ~~~reference in the article tha T Mr. Jordan mr ht 

I 13 I have heloed her get a job as part of some 9. hung to 

i14jdo with ths who& allegation? 

A I dont ’ know if she stated that or 

!:ziif I read it. because I then went out and bought 

at these meetings? 

1241guys125; Q What do you mean your ‘ guys”? 

Page 50 

A The people that I met with. 

Q You mean the FBI agents? 

A Yes. 

Yes. I had an internal meeting to 

l ii jexplain to my staff what was going on. to the best 

[l:!of-Imean,whatwasgomn&onutthepress. 

[II Jbecause we are a public re 

( 13 1 how to handle press calls. 

bona department, and 

114’ 0 What was the decision about how to 

1 I 51 handle the matter? 

A That because we were directly 

! f;jinvolved that we would work with Mad\ndrews 8 

i f 3 j Forbes public affairs and Robinson Lehr to handle 

[ 14 1 all the press calls. 

0 Was any actiin taken in regard to 

i I ! i the status of Ms. Lewinskr;s ‘ at beast then pending 

i 2 2 1 beginning work at Revton. 

!,i- A Yes. We rxrt the iob offer on hold. 

i 5; i I knew that from our press statement. I24 

i251 0 Were you invoived in any of the (25 

Page 51 

:z 1 meetings where any decision was made as to whether 

[ 3 1 or not to allow her to come on board or whether to 

[4]put a ho@ on it? 

15: A No. 

Q Did you have any degree of. any 

i ; j involvement with that? 

A It would have simp 

iii information from the department a x 

been relaying 

er learning 

~olfrom other people within Revlon or Ma&tdrews 8 

r111Forbes. 

t1:1 Q About what decision had been made. 

A Yes. I readthe 

t::icaseweneededtouseit. Tha #?= sreallywherel 

as statement in 

rlslleamed it. 

i i ,” i decision? 

Q But you werent ’ involved in the 

ii8j A No. 

Q 

! f,t ‘ of anv involvement with Ms. Lewinskv? 

Anything else beyond that in terms 

.-~, _ 

i2:j A No. 

Q Have you had any contact with Ms. 

i~~~Lawinsky, erther directly or indirectly, through 

[24! her counsel or an one else since your call which 

[? 5 lwould have been 1 elkng her you thought she would 

Page 52 

[ii 

~~11 tit in the depahrnent? 

I:; 

A I dont ’ think so no. 

Q Lets ’ take a diierent date. 

Have you had any contact with Ms. 

ii 1 Lewinsky or any representatives of hers since news 

17 1 broke aboit th%;!legatrons? 

A No. 

Q 

!:iinotes. I think we are about done. 

Let me take a second and check my 

122 1 when you were intr!r!!~ $ !%e&%a%dofkeep 

..--> 

t 2s ) in mind these are their notes, they could be 

[ 2~ 1 inaccurate. I want to make sure you are aware of 

[ztjlthat. 

Page 53 

[II 

121 The notes indicate that Ms. Shekton 

[ 3 1 indicated to you that Ma. Lewinsky would start on 

(4lJanuary 28, 1998. 

t51 Does that sound accurate to you? 

A It does sound accurate, yes. It 

i;ldoes sound accurate. 

I / r&uMh(;he;; ou woutd O‘ ” have betiive told that the that agents is when you 

illi A Yes. 

Q And you believe that that was 

I i: i accurate information? 

[I41 A To the best of my recollection. 

1151 MR. BIENERT: I think thats ’

[I61 all I have. 

[I71 MR. BINHAK: Nothing. 

1181 Thank you for your time. 

1191 (Whereupon, at 11:25 oclodc ’

[201 a.m.. the deposition was concluded.) 

i211 

1221 

1231 

Page 54 

CERTIFICATE 

I: NOTATE OF NW YORK ) 

tqCO”NT& NEWYORK) 

I51 

161 I, ANNETTE FORBES, a Certified 

[71 

ISI 

191 

IlO1 

[Ill 

t121 

I131 

[I41 

I151 

[161 

[171 

(181 thereof. 

I191 IN WITNESS WHEREOF, I have 

I201 hereunto set my hand this 28th day of 

1211 April, 1998. 

- 
3647 

OK-302 (Re\ s-19-94) 

- 1 

OFFICE OF THE INDEPENDENT COLTVSEL 

2/24/98 

Dare of trmscnpc,on 

BILLIE B. SHADDIX, white male, born 

Social Security Account Number-, home - ad ress 

1 - home telephone 

number I_, was interviewed in the Oifice of the 

Independent Counsel, 1001 Pennsylvania Avenue, N-W., Suite 490 

North, in the presence of his Attorney, D.E. WILSON, JR. of the 

law firm of Shook, Hardy & Bacon, Market Square West, 801 

Pennsylvania Avenue, N.W., Washington, D-C. 20004, telephone 

number 202-783-8400. 

After being advised of the personal and official 

identities of the interviewers and the purpose of the interview, 

SHADDIX provided the following information: 

Until retirement in 1987, SHADDIX was employed as 

Director, White House Photographic Office, Ground Floor, West 

Wing, telephone number 202-456-9411. Since retirement SHADDIX 

has been employed as a consultant for the same White House. 

SHADDIX works one or two days per week in a predominately 

administrative capacity that includes writing evaluations on the 

photographic staff, job descriptions, and purchase 

justifications. SHADDIX described the function of the White 

House Photographic Office as being responsible for a 

comprehensive visual documentation of each President for 

historical files and posterity. 

SHADDIX met MONICA LEWINSKY when LEWINSKY was an intern 

and would come to the Photographic Office to pick up photographs 

ordered by the Chief of Staff's Office. After =WINSKY began 

working for Legislative Affairs, LEWINSKY continued to 

periodically come to the Photographic Office to pick up 

photographs for that Legislative Affairs. 

The photographs that LEWINSKY picked up were stock, 

routine photographs, taken at various functions involving the 

President. No written request or other paperwork is required for 

White House staff members to obtain photographs of the President 

or other group pictures. 

SHADDIX recalls LEWINSKY making one request for a 

specific photograph in which LEWINSKY's brother appears with the 

President. There may have been other requests for specific 

Investi_earwn on 2/23/98 at Washington , D.C. Fdr# 29D-LR-35063 

SA 

by CI 

_. 

Daw d~crartd 2/24/98 
3648 

OIC-3023 (Rev. 8-19-94) 

29D-LR-35063 

B,ILLIE B. SHADDIX 2/23/98 2 

lation of OIC-302 of , On , Page 

photographs; however, SHADDIX cannot recall any others at this 

time. 

While LEWINSKY was employed in the White House, SHADDIX 

did not see LEWINSKY with the President or in the vicinity of the 

Oval Office. SHADDIX does recall seeing LEWINSKY, on one 

occasion, in the West Lobby area; however, SHADDIX did not know 

the purpose for LEWINSKY being there. 

SHADDIX has no knowledge of LEWINSKY's specific work 

assignment or how well LEWINSKY performed her job. SHADDIX has 

no knowledge of why LEWINSKY left Legislative Affairs, nor has 

SHADDIX heard any rumors or gossip about LEWINSKY's job 

performance. 

SHADDIX has heard no rumors or gossip about LEWINSKY 

having an affair with anyone in the White House. 

SHADDIX was shown a copy of a WAVE record (Bates 

stamped V0006-DC-00000007) which lists SHADDIX as the Requestor 

and Visitee of LEWINSKY on October 24, 1996. 

Prior to the interview today, SHADDIX reviewed files of 

the Photographic Office and determined this visit was to allow 

LEWINSKY to enter the White House and come to the Photographic 

Office to look for a specific photograph. SHADDIX recalls this 

particular visit was requested by an assistant to KEN BACON at 

the Pentagon. SHADDIX could not recall the name of BACON's 

assistant. SHADDIX could not recall the subject matter of the 

photograph for which LEWINSKY was searching, or'if LEWINSKY ever 

found the photograph. 

Since LEWINSKY left the Legislative Office, SHADDIX 

recalls seeing LEWINSKY in the White House approximately five 

times. SHADDIX has seen LEWINSKY near the Mess and the guard 

desk in the West Wing, ground floor. SHADDIX has no knowledge of 

why LEWINSKY was in the White House on these occasions. LEWINSKY 

was not with anyone at the time SHADDIX saw LEWINSKY. 

During this period to time, SHADDIX was working a 

6:15am to 3:30pm shift, usually on Monday and Thursday. 

SHADDIX has had no contact with anyone regarding this 
3649 

OIC-302~1 (Rev. S-19-94) 

29D-LR-35063 

BtLLIE B. SHADDIX 2/23/98 3 

Continuation of OK-302 of . On Page - 

interview; however, SHADDIX was telephoned recently by S;-:ELL< 

- 

PETERSON, an Attorney in the White House Counsel's_Office, 

advising his name appeared on WAVE records relating to LEWINSKY 

and that SHADDIX would probably be contacted by someone from the 

Office of the Independent Counsel. PETERSON did not suggest to 

SHADDIX what to say during the interview. 
3650 
3651 

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

- 1 - 

OFFICE OF THE INDEPEh-DENT COUNSEL 

Date of tfanscription 06/09/98 

WILLIAM CLAIR SHEGOGUE, white, male, date of birth 

a-4, Social Security Account Number _ 

Officer, United States Secret Service (USSS), was interviewed at 

the Office of the Independent Counsel (OIC), 1001 Pennsylvania 

Avenue, NW, Washington, DC, 20004. Present for the interview 

were Associate Independent Counsel (AIC) MICHAEL TRAVERS, AIC 

MARY ANNE WIRTH and Department of Justice (DOJ) attorneys ANNE 

WEISMANN and DAVE ANDERSON. SHEGOGUE was interviewed under the 

terms of an agreement reached between the OIC and DOJ. SHEGOGUE 

was apprised of the official identities of the interviewers.and 

thereafter provided the following information: 

SHEGOGUE has&een employed by the USSS since October 2, 

1972. SHEGOGUE has held numerous positions in the USSS, 

including many assignments at the White House. SHEGOGUE worked 

in the K-9 unit for six years until July of 1997. In July of 

1997, SHEGOGUE was assigned to the White House, but held no 

permanent post until October of 1997 when he was assigned to the 

-post. In March of 1998, SHEGOGUE was assigned to the Special 

Operations Division, a position he currently holds. 

The only time SHEGOGUE recalls that he may have seen 

MONICA LEWINSKY was in July or August of 1997, the day before the 

President left for Martha's Vineyard. 

a Saturday, 

SHEGOGUE recalls it being 

as that is usually his day off. 

SHEGOGUE was working at the 0 post, which is the 

_* SHEGOGUE was provided two diagrams of the 

layout of the First Floor of the White House. All of the 

handwriting on the diagram is SHEGOGUE's. 

these diagrams is attached to this FD-302. 

A reduced copy of 

The original diagrams 

were placed in an FD-340 along with the Agent's original notes of 

the interview. 

SHEGOGUE advised that between 9 a.m. and 12 noon, he 

recalls seeing BETTY CURRIE, accompanied by a young woman, coming 

up the stairs located immediately to SHEGOGUE's right. SHEGOGUE 

advised that he was friendly with CURRIE and paid more attention 

to her than to her guest. (SHEGOGUE advised that at the_L 

post, he faced w-b) SHEGOGUE did not recognize the 

woman accompanying CURRIE. 

Investigation on 06/05/98 at Washington, DC File I 29D-OIC-LR-35063 

by SA Date dictated 06/09/98 
3652 

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

29D-OIC-LR-35063 

CONinIMtiOn of OIC-302 of WILLIAM CLAIR SHEGOGUE .on 06/05/98 .hge 2 

SHEGOGUE advised that CURRIE and this woman went behind 

a door to a hallway which leads to the Oval Office. SHEGOGUE 

advised that he lost sight of CURRIE and her guest once they got 

behind the door, and he does not know where they went. SHEGOGUE 

advised that he had heard earlier in the day that the President 

had moved from the Residence to the West Wing complex. 

SHEGOGUEZ advised that he got to know CURRIE when 

SHEGGGUE was assigned to the K-9 unit. CURRIE would often have 

treats and food for SHEGOGUE's dog. SHEGOGUE advised the dog 

died last year, and CURRIE expressed her sympathy to SHEGOGUE. 

: k 

SHEGOGTJE advised that CURRIE would usually talk to him 

whenever they saw each other. On this occasion, CURRIE did not 

say anything to SHEGOGUE when she and her companion walked past. 

SHEGOGUE advised that five minutes later, CURRIE walked 

past SHEGOGUE by herself. CURRIE crossed the colonnade into the 

-Palm Room. SHEGOGUE does not know where CURRIE went, but advised 

she could have gone into the Residence, to the parking lot, or 

she even could have gone into her office. SHEGOGUE advised that 

it is probable CURRIE went to her car. SHEGOGUE advised it is 

unlikely CURRIE went back to her office, because the most direct: 

route would have brought her back by SHEGOGUE and SHEGOGUR did 

not see CURRIE the rest of that day. SHEGOGUE advised that when 

CURRIE passed him on this occasion, CURRIE said hello. 

SHEGOGUE drew arrows on diagram #l, indicating the path 

CURRIE and her guest took to the hallway leading to the Oval 

Office, t,he path CURRIE took to the Palm Room, and the paths 

CURRIE could have taken after SHEGOGUE lost sight of her near the 

Palm Room. 

Later that same day, SHEGOGUS was having lunch in the 

D-10 break room when Officer STEVEN PAPE mentioned MONICA 

LEWINSKY. (SHEGOGUR advised it went against everything he 

believed in to reveal PAPE's name to investigators.) SHEGOGUE had 

never heard LEWINSKY's name prior to this occasion. PAPE said 

that CURRIE came to the Southwest gate and escorted LEWINSKY into 

the White House. 

SHEGOGUE advised that it was unusual for the 

President's secretary to escort people, but since it was a 

Saturday, no one else was there to do it. SHEGOGUE advised that 

he could not swear the woman he saw with CURRIE that day was 

LEWINSKY. SHEGOGUE next saw LEWINSKY on television_ 
3653 

OK-MLa (Rev. 8-19-94) 

29D-OIC-LR-35063 

COMIllMtiOn Of 0ic-302 Of WILLIAM CLAIR SHEGOGUE .on 06/05/98 .plgc _3_ 

SHEGOGUE advised that he has heard many rumors about 

LEWINSKY, but he can not recall the details of most. SHEGOGUE 

recalls one rumor that the President was caught in the Family 

Theater with LEWINSKY. SHEGBGUE advised that, if the President 

was in the Family Theater, USSS Agents would not allow anyone to 

walk in. SHEGOGUE added that the only time an Agent would walk 

in on the President would be if ICBM's were headed toward the 

United States or if someone jumped the White House fence. 

SHEGOGUE advised that he does not know the true story 

regarding LEW FOX. SHEGGGUE advised that, if the President was 

in the Oval Office, the Uniformed Division officer would.be 

located at the past 

believes to be the 'post. 

& -, a which SHEEOGUE 

SHEGOGUE advised he found it 

extremely hard to believe that FOX would usher anyone into the 

Oval Office. SHEGOGUE advised he never saw it happen. SHEGOGUE 

advised it could happen, although it did not typically. 

SHEGOGUE knows FOX as the two would see each other at 

the White House. SHEGOGUE is not friends with FOX and he has 

never heard anything negative about FOX. 

SHEGOGUE marked on diagram #2 as to where he assumed 

FOX was stationed when FOX saw what he is reported to have seen- 
3654 

.:*,, First floor 

nu km-r Lnl 

RtMnn 
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In rc: Grand Jury Proceedings Multi-Page% Tuesday, August 4,1998 1 

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WILLIAM CLAtR SHEGOGUE 

was calkd as a witness and. having bmr first duly swom by 

the F-on of tbe Grand Jury, was cxamhcd and tcstifud 

as foihvs: 

EXAMNATION 

MR. PAGE: AU ri&t. WC arc ptcsnt with a quorum 

and no unauthorized pasons? 

THB FOREPERSON: l-bat’s CO~IUX 

THE DEPUTY FOREPERSON: Excuse me. Could ‘WC wai 

tili we @ve tbcse out? 

Q 

MR. PAGE: Yes. 

(Tk Deputy Forepa-son passes out documents.) 

THE FOREPERSON: Ohy. We’n: rtady. 

BY MR. PAGE: 

Would you tcil us your full nam& pkas~ and spell 

your last name. 

A Okay. Full name is William Clair Shogue, last 

name spc.lM S-h-g-o-g-tit. 

Q And your placancnt of anplmt? 

A I’m anployed by the United States Seczt Sczvice, 

part of the W&c House Division. 

Q Anz you an officer? 

A I’m an off&r of the Secret Sexvicc Uniform 

Page 4 

1 Division. 

2 Q Officer Shegopuc. my name is Ed Page. I work for 

3 the Independent Gxtnsel’s Ofiice, and to my Mt is Mary Anne 

4 Wirtb. who I believe you’ve met bcfon. corfozt? 

5 A Correct. 

6 Q In front of you to your leti is the court qortc~ 

7 who is taking down everything that is said today, so that an 

B ofticial Rcord can be made of what is in fact said bar: 

3 today. Do you understand that? 

3 A I understand. 

1 Q Beyond the iawyus pnscnt and tk court reporter 

2 aKtbcrrxzn~softbcgrandjtuybcarhgthismattcx. Do 

3 you undustand that? 

1 A Yes. fdo. 

5 Q &fort I ask questions of you and bcforc Mary Anne 

5 Wirth, my cohguc, asks questions of you, I’d like to 

7 explain some things to you. all right? 

3 A Okay. 

3 Q Fmt of all. do you understand that all matters 

S occurring before this grand jury ate secnt U&J law? 

1 A Yes, Ido. 

2 Q Do YOU ttndcrstand that ncitkr tbe ammeys, the 

3 grand jury or tbc court n+xtez can disclose what you say 

4 tmtodayunkssacourtordc7sitdisclosaiarsomc 

5 otcepticmismc? 

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A 1 ~understand that. 

Q I)0 you understand that even absent a court order. 

however. you have the ability after you make your appearance 

here today to tell others about what you have said during 

this gzand JUry session? 

A I’m aware of that also. 

Q Do you understand that undo the law you have 

certain R&S wben you appear in front of a f-1 grand 

jury? 

A Yes. 

Q ~d~~~~~~~youat~s~~e 

sure that you do koow what they are and that you understand 

them. 

A Okay. 

Q Fiit I want to advise you. and I rep-t to 

you, that this federal grand jury is conducting an 

investigation of possible violations of fakral criminal laws 

involving wbzth Monica Lzwinsky or other suborned perjury, 

obstructed justice. intitnkiated witnesses or otbrrwise 

viola&xl federal law 0th~ than a Class B or C misdemeanor or 

infraction in dealing witb witnesses. potartial witnesses. 

attorneys or others concerning the civil case Joocs v. 

Clinton. 

A Iunderstand. 

Q You may refuse to answer undo the Fifth Amendment 

n r-e: Grand Jury Proceedings Mult 

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any question if a truthful answer to the question would tend 

to incriminate you. Do you understand that? 

A I understand. Yes. 

Q Do you understand further that anything you do say 

may be used against you by the grand jury or in a subsequent 

legal proceeding? 

A I understand that. 

Q Do you understand further that if you have a 

lawyer, the grand jury will permit you a reasonable 

opportumty to step outside the grand jury room to consult 

with that lawyer if you want to? 

I’m aware of that, yes. 

Do you have a iawyer p-t? 

Ye-s, 1 do. 

Would you tell us his name? 

Man Dates. 

Do you understand that you can step out, as I’ve 

just mcntioncd, and speak with him at any time during the 

questioning today? 

0 A Yes; I’m aware of that. 

1 Q Do you understand, and I represent to you, that 

2 them arc two kinds of witnesses who appear before the grand 

3 jury? One. is a target; one is a subject. 

4 Atargetisapersonthatthcgrandjuxyhas 

5 substantial evidence linking them to the commission of a 

i-l 

7- 

Pagem Tucsday, August 4, 1998 

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n)^,.- - 

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federal crime and who is a - what’s called a putative 

defendant. or somcmc that the prand jury iateads or is 

considaing indicting. 

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I reprcsax to you thax you an not a target and 

that you fall into a different class of gmod jury titnc?& 

and that is tk class eotitlal or calkd subpct. Within 

that class of graod jury wimcsscs tbcre are a wide array or 

expanse of people that fit in that. For example. a bank 

teller who may have sren the commission of a bank robbery may 

lx. at socue times calkd a subjuz, meaning that tbzir conduct 

is within the scope of the grand jtuy’s investigation, 

because there may be cvidaxc that tbe teller is involved in 

helping tlz r&bay occur. Do you undmtand? 

A Comet. Yes; I unkstand. 

Q Ontbeothxhandattbeotkrendoftbespecmun. 

tbe bank tek who bad no involvement 0th than tbe fact 

that the bank teller was robbed is also con&xxi a subject 

within this broad dehition even though no one suspects that 

tbe teller was involved. All tky believe is tbat the teller 

was a fact witness. 

I rcprcscat to you that you are, as wc stand bcre 

now, a fact witness. 

A Iunderstand. 

Q Do you understand? 

A Yes. sir. 

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Q That you, because of things that you did in the 

past, where you worked, things you saw and heard may have 

relevant information to this grand jury’s inquiry. 

A Iunderstand. 

Q All right. You took an oath a few minutes ago, and 

I want to spend a couple of minutes there or less. Number 

one, do you understand that you’re obligated to tell the 

truth here, and that means the full truth, the candid truth, 

and that you could be prosecuted for perjury or obstruction 

of justice if you chose not to give the full or candid truth? 

A Iunderstand. 

Q Do you understand further that you can’t say, and 

it would be a violation of your oath to tell the truth, that 

you don’t remember something when in actuality you do? 

A Iunderstandthat. 

Q And do you understand, finally, that you can’t give 

otherwise misleading ansulas when your intent or goal is to 

mislead the grand jury or others? 

A Iunderstand. 

Q Do you have any otkr questions of us before Mary 

Anne Wirtb starts with your questions? 

A No, I don’t. 

Q Thank you. 

A You’re wehxxne. 

BY MS. WIRTH: 

PageS-Page8 

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Q Okay. Officer, you are employed by the Secret 

Service, correct? 

A That is correct. 

Q And you’ve been so employed since 1972? 

A ‘Ibat is atso czmrect. 

Q And for six years, until July 1997, you worked in 

the K-9 Unit; is that right? 

A ~i~s~~p~or~~~~k~~ 

White House, yes. 

Q Okay. Wheo did you come back to the White House? 

A Icameback--ma&nedinJulyofla.styear, 

1997. 

Q Okay. Can you tell the grand jury what the K-9 

Unit is briefly? 

A In our K-9 Unit we have bomb dogs. They detect 

explosives. There are also or at least were at one time also 

trained in protection work of the handler, and if we felt it 

necessary, we could also send them on an attack of a flging 

subject involved in a felony. 

.Q Okay. You told us that in July of 1997 you were 

assigned to the White House, correct? 

A That’s correct. 

Q And throughout your career, you have previously 

been assigned to the White House at times; is that true? 

A That’s also correct. 

Page 1c 

Q Now, in October of 1997, you were assigned to the 

D4 post; is that right? 

A That’s correct. 

Q And can you tell the grand jury what that is, that 

post? 

A D4 post is a post that’s tocated on the southwest 

comer of the Old Executive Office Building It’s an exit -- 

vehicular exit post and pedestrian -- I don’t want to use the 

word pedestrian, because we just don’t have pedestrians in 

there. Its ’ a exit for staff also. 

Q Okay. Now, in March of 1998, you were assigned to 

the Special Operations Division; is that right? 

A That’s correct. 

Q And do you currently hold that position? 

A I do. 

Q And what is, briefly, Special Operations Division? 

A Special Operations Division handles all tours of 

the White House, both public and guided tours. We aiso are 

involved in all of the social events that occur at the White 

House, and any other event that may occur that requires 

checking people into the house, and also standing in various 

positions throughout the house in security function. 

Q Now, can you recall a time when you may have seen 

Monica Lewinsky? 

A Yes, I can. 

Page 1 

I Q Okay. Can you tell tbc grand jury wbm that was? 

2 A To the best of my rrcolktion, tt was sometime in 

3 August 1997. 

4 Q And was there a patticular evcot that was about to 

5 happen at ti White House that you connect with se&g her? 

6 A Yes, I do. It was the date - fast off, it was my 

7 day off wbicb was Saturday. I can mnanber. It was also tk 

8 day before the First Family was going to Marthas ’ Vineyard. 

9 Q Aad what post wue you working that day? 

0 A Iwasworkingwhatwccall~ 

I Q Andtellthcgrandjurywhat_is. 

2 A -is a post located - if you have tbc maps, it’s 

3 located-j It’s basically 

4 c”‘w. Tbzy could come 

5 throughtk~. lhcywouldbavetogopastmy 

6 posttogotowbattbeycalltk~. Tharc 

7 they would go in and see basically the -_ 

a_&. That is a control post for that 

9 purpose of making sum those that go into the _ 

0 w arc authotizcd. 

1 (Grand Jury Exbjbit WS-1 was 

2 marked for idattification.) 

3 Q Okay. I’m going show you whai’s ban marked as 

4 Grand Jury Exhibit WS-1, your initials, okay? 

5 A Yes. 

Page 12 

1 Q And I’m handing you a blue pen. Does this map look 

2 Iike the West Wing? 

3 A Yes. 

4 Q Okay. Can you mark with m the spot where them 

5 post is. 

6 A Withan “x?” 

7 Q You can write -where -- 

8 A Wait a minute -- I guess if I can follow the map 

9 hue (marks document.) 

0 Q Okay. And I’m going to direct your attention to a 

1 set of what appear to be stairs. 

2 A I-bat’s correct. 

3 Q And you and I have talked previously, right? 

4 A Correct. 

5 Q And part of the story that you’re going to tell 

6 concerns those stairs; is that comet? 

7 A That’s correct. 

6 Q And Iooking at that, does that refresh your memory 

3 as to w-is? 

3 A Uh-oh. I guess it does. Your map is a little 

I extended out there. Let‘s put I)where it really belongs, 

2 right here (marking document). I was wondering where that 

3 wall came from. 

1 Q Can you cross that out? 

5 A I will cross that out. 

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And just put your initials over there. 

Sorry about that. 

And could you -- 

1 don’t nonnally‘look at this map. 

That’s all right. ‘Ihat’s no problem. 

Okay. 

Just take this red pen and circle in red where you 

did put AEIUE and where you know -to be. 

A (Marking document.) All right. 

Q Now, when you’re sitting at the m post -- 

actuaIly, I just asked you a question in my question. 

A What? 

Q Do you sit at m 

A I have sat at-, yes. 

Q And the day we’re going to talk about, were you 

sitting? 

A Iwas. 

Q And what direction were you facing? 

A I would be facing _ out towards the a 

w and basically the 

Q All right. Now, did there come a time that day -- 

well- let me take that back for a minute. Do you remember 

what your shift was that day, what hours you were working? 

A I was working the day work shift, 0630 to 

approximately 144 5. 

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Which is 2:45 in the afternoon? 

Thats ’ correct 2:45 pm. 

Did there come a time that day when you saw some - 

A JUROR: I’m sorry, Mary Anne - 

MS.WIRTH: Yes. 

A JUROR: Can you tell us w-s please? 

MS. WIRTH: Sure. I’ll just take &is, excuse me. 

THE WITNESS: Sure. 

(Ms. Wirth displays the map to the jurors.) 

BY MS. WIRTH: 

Okay. So did there come a time that day when you 

2 saw something or saw someone or persons? 

3 A Yes. 

4 Q Doyou remember approximately what time that was, 

5 if you know? 

6 A Approximately - I’m sorry I can’t narrow it down, 

7 it wasn’t just a n-1 happcoing in the West Wing. I would 

B say it was probably sornewlue between 9:00 maybe 1O:OO in the 

3 morning to prior to noon, somewhere in that area. 

3 Q And what did you see? 

1 A I saw the President’s press secretary - not press 

2 secretazy - I’ve got press on my mind - the President’s 

3 secretary, Betty Currie coming up the stairs, at that time 

4 to my right where I was sitting, with a young lady. 

5 Q Okay. And was there anything about that person, 

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tire young lady, that you could describe in terms of her 

appearance? I 

A TbebestthatI temember,Ihadnevuseenthat 

lady prior to this time. I could say that she had dark, 

black type hair. 

Q Okay. Now, you said that you saw tkm coming up 

stairs? 

A Gnnitqupthestairsyes. 

Q Okay. Could you take this blue pen and just circle 

tlz stairs that you mc3tl. 

A 

Q 

WY. 

A 

Q 

A 

Q 

(hkking document.) 

Okay. La me s& wbza-e we’re talkiug about he. 

Now. west tky mgetber? 

Yes. they wae. 

And do you know Betty Currie? 

Yes, I do. 

Can you just tell the grand jury - briefly 

describe your relationship with her. 

A I would say our relationship is very cordial. When 

I was in our K-9 Unif we would search all &ticles coming on 

to West Executive Avenue. Her vehick was one of many coming 

12 on the avaxte. I will say to Betty’s attributes. she is 

‘3 probably one of the friendhest staff members and also a 

4 great dog lover. And she had a tendency to spend a little 

5 extra time talking to the dog, not always to us but at least 

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to the dog. and she also loved to give the dogs a treat. And 

any time she came by, you can believe all the dogs knew she 

w-as there, and they were always up at her window waiting foi 

the treat. And that just fostered a friendship amongst us, 

and again very cordial. 

Q Now, is there something that had happened with 

respect to your dog at or about this time? 

A Yeah. 

Q I’m sorry to -- 

A Yeah. They had retired my dog in June, late June, 

because of a leg problem that he had. He was injured in 

training. I don’t know if you need all this story -- 

Q No, it -- 

A -- but I’m going to tell it. He was injured in 

train@priortomeevergertinghim. Hetoresome 

ligamentsinhisrightrearle&andthatwasbasicallyhowI 

got back into our K-9 program. Our job is not necessarily 

oneto- once your job goes, you basically go as far as K-9 

is concerned, you still stay in the uniform division. 

BemusebewasinjuredbecauseIhadb&ninK_9beforeand 

in our K-9 Unit before, they needed a handler they felt that 

could kind of bring him along. So -- mm -- certain things 

you try not to bring up to close, a little difficult. 

Anyways,soIspentsixyearswithmydog,Bany,andiikeI 

said,hisieggottoapointwherehecould-theyfeltbe 

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3661 

In x-e: Grand Jury Proceedings Multi-Page M Tuesday, August 4, 1998 

Page 17 Page l! 

1 could no longer perform adequately at his job. So, anyway, I Q --just to the left of the staircase. 

2 they retired him, and I went on a brief vacation, came back, 2 A Correct. 

3 and~ormnatelythe&yafterIcameback,hehadaheart 3 Q Was that door open or closed when they went tt-ough 

4 attack. 4 it, if you know? 

5 Q And that was very close in time to this incident; 5 A As I can recall, I believe the door was closed. 

6 isthatcomzct? 6 Q And did they close it behind them? 

7 A ‘hat’s correct, within I would say a month. 7 A Yes. It pretty much closes itself. Once you go 

8 (Whereupon, Jackie M. Bennett, Jr. enters the grand 8 through it, it will close behind you I believe. As I recall, 

9 jury room.) 9 Ithinkitdoes. 

0 Q Okay. And when you saw Betty Currie that day, you 10 Q Okay. And that path that they took -- and I’m 

1 werethinkiqofyourdogatthattime;isthatri&t? 11 goingtoaskyoujusttoattheendofthegreeniinetojust 

2 A Yeah. 12 draw an arrow indicating the direction they went. 

3 Q And then that’s why this incident sticks in your 13 A Mm-hmm (drawing). 

4 mind to a certain’extent? 14 Q Is that a natural path to the Oval Office? 

5 A Toacertainextenfyes. 15 A Yes; it would be from there. Yes. 

6 Q Okay. By the way, was Betty Currie friendly with 16 Q Okay. Now, do you have any memory of where the 

7 you that day? Did she speak to you? 17 President was that day? Do you have a memory of wktber hc 

8 A That was a little bit unusual for that day. As I 18 was -- 

9 looked to the right and saw her coming up the stairs with the 19 A Yes. We’re always made aware of where he is as 

o young lady, really didn’t pay too much attention to the young 20 long as we’re in the wing, and he was in the Oval Off~i~ at 

1 lady, I was -- because I didn’t know her. As recognizing 21 that time. 

2 Betty coming up, I always said hi to her. I don’t reeaU ha 22 Q Okay. Do you have any memory at all of how long he 

3 even saying hi back She may have, but if she did, it was 23 had been there at that point? 

4 more subdued than usual. She’s very bubbly, and again, 24 A Let’s see, it was a Saturday morning. It’s hard to 

5 because of this dog thing we had going, always -- and I would 25 say. On a normal day, he would usually show up in the area 

Page 18 Page 20 

1 even say sometimes over friendly. It wasn’t unusual to get a 1 of around nine o’clock. On a Saturday. howeva. if he bad 

2 hug from her if she came by, you know, whatever. And that 2 things - other things to do. he could get thenz earlier. I 

3 day, just -- that’s kind of why it stuck in my mind, although 3 can’t say bow long hc had been in tbx, only that he. was in 

4 I played it off as no big deal. She obviously had someone 4 thcrc. 

S with her, so, you know, it’s not my job to sit there and have 5 Q Okay. Now. can you tell us what happcncd next? 

6 conversations with her. So I .&In? pay a whole lot of 6 Did you ever sa Betty again? 

7 attention to it, but it did -- you know, I did -- 7 A Yes, probably witin 5 or 10 minutes from that 

B Q Itregistered? 8 time. 

9 A It registered. Exactly. 9 Q Andwbaetiidyouseehcr? 

3 Q All right. Now, can you tell us what path she and 10 A Again. coming back through that closed door. 

1 this dark haired woman took when they came up the stairs? 11 Q Okay. Through the same door that sbc and the dark 

2 A When they reached the top of the stairs, they made 12 haircd woman had gone through? 

3 a -- basically a left, a u-turn if you will, in that they 13 A That’s correct. 

Q went directly around to the left, heading towards the Cabinet 14 Q Did she come out alone or with somaJnc else? 

5 Room, of course next to the Cabinet Room is her office, and 15 A She was alone. 

6 that was expected, the direction which she would normally 16 Q Andwhatdidshcdotkn? 

7 travel. 17 A She then pmccedal basically towards my post, 

B Q Okay. I’m going to give you this green pen and ask 18 making a right as you would going down tk colonnade arca 

9 you, from the top of the stairs, to just draw the path that 19 into what appcarcd to be at least in tbc direction of the 

D you saw them take. 20 mansion. 

1 A Okay (drawing). 21 Q Okay. And did sbe greet you this time? 

2 Q And basically you’ve drawn in a hairpin turn off 22 A I - yes. sbc did. a friendlia wing but again 

3 the staircase, and you’ve drawn a line through what appears 23 I kind of took it as a praccupied -- I mean it was a 

Q tobeadoor- 24 greeting, but I could she had other things on her mind as she 

5 A That is correct. 25 was going by. l%ere was no bugging. Tberc was no, you know, 

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In re: Grand Jury Proceedings Multi-Pagem 

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Tuesday, August 4,1998 7 

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over introduction or hello or anything else. She did say hi, 

though. 

Q I’m going to give you this red pen and ask you to 

draw the path that she took starting from -- 

A From where I saw her come through? 

Q -- the door. 

A (Drawing) LetmeseeifIcangetthisright. 

This is the end. 

I MS. WIRTH: Thank you. 

2 (A brief recess was taken.) 

Q Okay. And you’ve drawn an arrow - basically, 

you’ve drawn a path with the red pen going from this 

staircase past your post at= off past the- 

_, and then off to the end of the diagram? 

A Correct. 

Q And what are the possible places that Betty could 

have ken going if she was going in the direction that you’ve 

dram here? 

A Well, what I would believe would he the most 

logical place would he in the mansion itself, at least the 

ground floor portion of it. 

Q Is the parking area also off that area? 

A There is a parking area over on East Executive 

Avenue, but again you’d have to go through the mansion I 

would say. 

Q Okay. How was Betty Currie dressed that day, do 

you remember? 

Page 22 

1 A I couldn’t tell you exactly what she had on. but it 

2 was more or less casual. but Betty even casual was still well 

3 dnssed. 

4 Q Okay. And did you ever see the dark hati woman 

5 again that day to your knowledge? 

6 A No. I did not. 

7 Q Okay. Did you later learn something that day about 

8 who tbat dark haired woman might be? 

9 A Yes. I believe I did. 

0 Q And could you tell the grand jury w&e you were 

1 when you heard this? 

2 A I was in our ana we call DIO which is basically 

3 our lunch room. 

4 THE FOREPERSON: Thcrc’s a knock at tbc door. 

5 (lntaruption to the proceedings.) 

6 MR. PAGE: Apparcndy tbc chief judge would like 

7 to soz tk F-on and the Deputy Forcpcrson at this time. 

8 THE FOREPERSON: Yes. You’ll have to cxcux - you 

9 want to take a break for 10 minutes? 

!O MS. WlRTH: Sure. You can step auf then. and 

!1 we’ll call you back in about 10 minutes. 

!2 THE WlTNESS: Just out in the hall? 

13 MS. WIRTH: You can go back to tbc room if you 

!4 want. 

15 THE WITNESS: Back to the room, sure. 

3 THE FOREPERSON: Officer Shegogue, I’d like to 

4 remind you that you are still under oath. 

5 THE WITNJ3S: Yes. 

6 THE FOREPERSON: Please have a seat. 

7 BY MR. PAGE: 

8 Q Officer Shegogue, we’re back on the record after 

9 thatrecess. Therearesoxnenewfacesinthegrandjuryroom 

10 but they are attorneys for the government, all right? 

II A Okay. 

82 Q We want to continue with your questioning, and we 

.3 just have a few more for you. Do you understand? 

,4 A Okay. Mm-hmm. 

5 Q I believe we left off with Mary Anne Wirth asking 

6 you about the diagram. 

7 A Right. 

8 Q And then she was going to ask you some questions 

9 about -- after you saw what you’ve already testified about, 

10 you later that day -- 

!I A Correct. 

!2 Q -- were having lunch in the D 10 break room, 

13 correct,? 

14 A Correct. 

15 Q DCJ you remember those e.vent.s of that day? 

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A Yes, to some mt. 

Q During your lunch break in DlO, did you happen to 

sa Officer Stcvcn Papc. 

A Papc, 3-b 

Q R_iglll? 

A Yeah. 

Q When you saw him. did you have a conversation with 

Pape? 

A Ihelicve-yes.Idid. 

Q Tell us what tk substanw of the convasation was. 

A At that time, the substance of tbc conversation was 

it was brought to my attention at that Point that Monica had 

just come in. 

Q MonA From - that’s all - that’s all k said, it was 

Monica had just come in. And my question to him, having 

ncverbeardtbcnamebcforcorsacnhakforr:was’Wbois 

Monica?” Statanent I believe, not quoting but in gcnaal was 

something to effect of a fomxr anploy& who has come in 

again today tn sa tk P&dent. Still, this was before 

anything b&c, so I was still in tbc dark asking him “What 

do you mean?” why would k cva~ bring it up for that matter. 

I didn’t understand that. 

Basically, hc advised me that sk had worked at the 

White House as an intun, and sk kft and had ban gone for 

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3663 

In re: Grand Jurv Procecdin~s 

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some time. He didn’t specitically say how long that amount 

of time was, and that she had ma& numerous visits back to 

the white House. I continued to question him I guess at that 

time as to “and what?” And it was said that she has been 

known to come in and visits the President fairly often. No 

number of times wuc discussed. 

At that point, I said “Exactly what does she look 

like?” and he described her basically as a young lady in her 

early twenties, as I recall, dark hair. I don’t think he 

even said how talI she was or anything. At that point, with 

thedarkhairandrememberIwastryingtoputtwoandtw0 

together, I said “About how long had this been?” And at that 

point, I think had been probably at least a couple of bouts 

fromtbetimeI’dseenwhatIsawintheWestWingtot.he 

time I was eating lunch. I can’t give a specific time w&n I 

waseatinglunch,whenIsawifbutIthinkbetweenthegap 

it was about a two hour or so break there.. And I asked 

again, I said “Well, where would she have come in?” I said 

“If you saw her, I can assume you’re on a specific post, she 

must have come through your ~0%” and he said “Yes, sbe 

did.” And said -- he also said that Betty Cunie came down 

to get her, which to me kind of put some antennas up, beca~ 

Betty Currie, as the President’s secretary, does not go down 

and get too many people. That struck me as being very 

unusual. 

Multi-Page m Tuesday, August 4, 1998 

/ 

5 Page 2 

1 get yourself -- you know, we’d call the person who cleared 

2 you in, and they can call the WAVES and clear in. 

3 From my understanding talking to him, this was not 

4 actually done. It was called directly to Betty Currie’s 

5 office lhe call was made from him, I believe, tbat Monica 

6 was there, and she’s not cleared in, and Betty said - to 

7 my -- I’m not verbatim saying that’s what she said, but 

8 basically said she will come down and escort ber in. 

9 The President’s secretary comes down to escort 

10 someone in, whether she’s cleared in WAVES or not, they’re 

11 coming in. That was the situation that day, all unusual to 

12 say the least, not normal. So that’s -- with all of that, 

13 and the fact that Betty brought her in and I put the timeline 

14 together, and a light clicked, that’s who I saw coming up 

IS with her. It fit within that time frame. And that’s 

1 16 basically what I know and why I know that was Monica with 

I 17 her, from our conversation. 

1 18 Q And do you know from what you’ve seen publicly 

I 19 since then that that is Monica Lewinsky? 

: !O A Definitely, yes. 

i !I MR. PAGE: All right. Would you mind stepping out. 

: i !2 THE WITNESS: No problem. 

2 !3 MR. PAGE: Thank you. 

2 !4 (The. witness was recalled at 1157 a.m.) 

2 !5 (Tbe witness was recalled at 1158 a.m.) 

Page 26 1 

I continued to question him as to why would sh 

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come down to get in? He basically stated “Well, it’s an 

appointment with the President, and she’s, bow do I put it. 

really not cleared to come in.” And tbat was a little 

unusual also. I said “When you say sbc’s not cleared to come 

in. does tbat mean there’s some mason sk can’t come in or 

she just hasn’t boeri clearad?” To be ckamd ta come into 

tk white House, someone staff-wise would have to caIl in not 

only your name to our WAVES system which I assume you have 

beard something about at this point. but tky would also have 

to get your social security number. Basically, it’s a quick 

background check to make sure you have no criminal background 

that Ucy should bc aware of, you’re not wanted for anything 

and so on and so forth 

So again questioning him a little further, k 

basically stated that she bad worked hz, she doesn’t work 

kre now, so for that reason she has no pass, so sk has to 

be cleasul in. Apparently, from our conversation, sk bad 

not been actually cleared in as an appointment which I 

tbougbt was, again, ratkr unusual if sbs would show up tbue 

for an appointmqnt and not be ckared in for that 

appointment. It happens on occasion. Some people forget to 

make tk call, or the caII is made. and our WAVES -- somewhere 

it gets lost along tbe track and it’s just not done, but you 

would normally just teIl the person caII back to WAVES and 

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THE FOREPERSON: Officer Sbegngue. I just wanted to 

let you know tlx31 -- we want to first thank you for your 

testimony. and you know. you are excused. And if tbcre are 

any additional questions. tbc attorneys will be in contact 

with you. 

THE WITNESS: Very good. 

THE FOREPERSON: Thank you very much. 

THE WITNESS: Thank you. 

MR. PAGE: Thank you. 

(The witness was excused.) 

(Wbrmnrpon. at 11:59 am.. the taking of the 

testimony in the presence of a fu.U quorum of the Grand Jury 

was concluded.) 

l +*t* 

Diversified Rmortinrr Services. Inc. (2021296-2929 

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3664 

In re: Grand Jury ProceedinRs Mull 

CERTIFICATE OF REPORTER 

I, Stacey B. Griffk, the reporter for the United 

States Attorney’s Office, do hereby certify that the 

witness(es ) whose tcstimcmy appears in the foxgoing pages 

was first duly sworn by tbc foxperson or the deputy 

foreperson of the Grand Jury when there was a full quoruxn of 

the Grand Jury p-t; that the testimony of said 

witness(es ) was taken by mc by Stenomask and thexaftex 

reduced to typewritten form; and that the transcript is a 

true record of the testitnony given by said witness(es). 

Stacey B. Griffin 

Official Reporter 

Pagem Tuesday, August 4, 1998 

Diversified Reporting Sewices, Inc. (202) 296-2929 

Page 29 - Page 29 
3665 

OIC-302 (Re\. g-19-94) 

- 1 - 

OFFICE OF THE INDEPENDENT COUNSEL 

2/2/98 

Date of transcrlption - 

JENNIFER L. "JENNA" SHELDON, white female, born _ 

_ Social Security Account Number q-1 home 

address b telephone 

employed as Manager, Human Resources, Reblon, 625 

Madison Avenue, New York City 10023, telephone {_l6, was 

interviewed in the offices of Attorney CHARLES A. STILLMAN of the 

firm of Stillman & Friedman, 425 Park Avenue, New York City, 

telephone 212-223-0200. Also present during the interview was 

JOHN B. HARRIS of the same firm. 

- 

After being advised of the personal and official 

identities of the interviewers and the purpose of the interview, 

SHELDON provided the following information: 

SHELDON first became aware of MONICA LEWINSKY on 

January 9, 1998, when ALLYN SEIDMAN, Senior Vice President for 

Corporate Communications, telephoned and requested SHELDON to 

interview a new applicant. LEWINSKY was brought to SHELDON's 

office where LEWINSKY filled out an application. SHELDON was 

aware from LEWINSKY's application that LEWINSKY had been referred 

to Revlon by JAYME DURNAN, a Vice President at MacAndrews & 

Forbes Holding Inc. and VERNON JORDAN, a member of MacAndrews & 

Forbes Board of Directors. SHELDON explained that MacAndrews & 

Forbes Holding Inc. is the holding company for Revlon. 

During the interview that followed, SHELDON asked 

LEWINSKY how LEWINSKY knew VERNON JORDAN. LEWINSKY said that she 

was a friend of JORDAN and one day had mentioned to JORDAN that 

she was interested in the fashion and beauty industry. SHELDON 

could not now recall what LEWINSKY said about how LEWINSKY came 

to know JORDAN if LEWINSKY even told her at all. 

No offer of employment was made to LEWINSKY the day of 

the interview. SHELDON later discussed LEWINSKY with SEIDMAN and 

they decided that LEWINSKY was qualified for a new entry level 

position of Public Relations Administrator that they had been 

discussing. The decision was made by SEIDMAN, DURNAN and SHELDON 

to offer the position to LEWINSKY. LEWINSKY's starting salary of 

$40,000 was agreed upon by the three of them based on other 

recently hired employees' starting salaries. 

Investigation on l/26/98 at New York City, NY Filet 29D-LR-35063 

Date dictated 2/2/98 
3666 

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

29D-LR-35063 

JENNIFER L. "JENNA" SHELDON l/26/98 2 

Contmuation of OK-302 of . On Page - 

On January 13, 1998, SHELDON telephoned LEWINSKY in 

Washington, D.C. and a verbal offer of employment was made. 

LEWINSKY accepted the offer immediately. SHELDON asked LEWINSKY 

for the names of references and by facsimile received January 14, 

1998, LEWINSKY provided the names of KEN BACON and JOHN HILLEY. 

SHELDON attempted to contact both references but both were 

unavailable. 

SHELDON did not feel undue pressure to hire LEWINSKY 

even though SHELDON was aware that LEWINSKY had been recommended 

by officials at MacAndrews & Forbes, Revlon's holding company. 

The position offered to LEWINSKY is a newly created 

position but the company fully intended to fill the position. If 

not with LEWINSKY, then with someone else within the near future. 
3667 

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

- 1 - 

OFFICE OF THE lNDEPENDEZ;T COUNSEL 

Date of transcription 

4/l/98 

JENNIFER “JENNA” L. SI-IELDON is employed as a Manager 

for Corporate Staffing, Human Resources, REVLON CORPORATON. She 

was interviewed at the law offices of STILLMAN & FRIEDMAN, P-C., 

425 Park Avenue, New York, New York. Present at the time was 

CHARLES STILLMAN, attorney for MC ANDREW & FORBES HOLDINGS, 35 

East 62 Street, New York, New York. Also present were Assistant 

Independent Counsels THOMAS BIENERT and STEVEN BINHAK. SHELDON 

provided the following information: 

As one of the Managers for Corporate Staffing, 

SHELDON's duties include recruiting employees for REVLON ranging 

from the clerical level to the director level. She supervises 

another person who assists her. Her immediate superior handles 

the senior executives recruited by the company. SHELDON reports 

to RICK POGUE, Vice President, Human Resources. The offer of 

employment made to MONICA LEWINSKY was considered entry level 

management. 

SHELDON first became aware of LEWINSKY on Friday, 

January 9, 1998 when she received a telephone call from ALLYN 

SEIDMAN, the head of public relations for REVLON. SEIDMAN said 

she was interviewing LEWINSKY and that she wanted SHELDON to meet 

with her thereafter. During the hiring process, an applicant 

seeking a position in public relations usually meets with three 

or four persons for assessment. The last person to meet the 

applicant would be the head of the department, ALLYN SEIDMAN. 

SHELDON interviewed LEWINSKY as requested. She asked 

LEWINSKY who she had already met at the company. LEWINSKY 

responded she had met JAYMIE DURNAN, ALLYN SEIDMAN, and NANCY 

RISDON (also in the public relations department). The purpose of 

the interview was for SHELDON to evaluate LEWINSKY. Prior to the 

actual interview, SHELDON had not seen LEWINSKY's resume, however 

was able to look over a copy LEWINSKY brought to the interview by 

LEWINSKY. SHELDON recalled LEWINSKY saying that she preferred 

the environment at the Pentagon over that at the White House. 

SHELDON explained that as a general rule, Human 

Resources meets a potential employee first, the opposite of what 

Investigation on 3/27/98 at New York, New York Filet 29D-OIC-LR-35063 

by SAa Date dictated 4/l/98 
3668 

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

29D-OIC-LR-35063 

JENNIFER L. SHELDON 3/27/98 2 

Continuation of OK-302 of . On , Page 

happened with LEWINSKY, however she did not find it particularly 

odd in this case. At REVLON, the different departments try to 

work as a partnership. SHELDON did allow it was irregular that 

the Human Resources department would not know about the fact that 

an applicant was in play for a position at public relations, or 

any other department. 

As she went through the interview process, SHELDON made 

notes on the applicant's resume. A copy of that resume was 

provided by CHARLES STILLMAN. A copy containing the notes is 

attached hereto. During interview, SHELDON was getting a sense 

of LEWINSKY's experience and abilities. 

The overall impression LEWINSKY made was that she was 

"fine" for employment. SHELDON also thought she was a pleasant 

person. As they talked, she found it hard to get a fix on where 

exactly she would fit into the organization. SHELDON had a 

better idea about that after she spoke with SEIDMAN and heard 

that SEIDMAN wanted her for her department. On her own, SHELDON 

had concluded that LEWINSKY was not suited for the Administrative 

Assistant or Public Relations Assistant. 

At the conclusion of the interview, SHELDON escorted 

LEWINSKY to the elevator bank. Before leaving, LEWINSKY 

mentioned that VERNON JORDAN had recommended her for employment. 

She said she was from Washington, D.C. and knew JORDAN. She also 

said she had an interest in the fashion and cosmetics industry. 

Upon returning to her office, SHELDON telephoned 

SEIDMAN to say the interview was over. In response to SEIDMAN's 

question as to her evaluation, SHELDON responded LEWINSKY was not 

qualified for a position. SEIDMAN then suggested a new position 

being created known as Public Relations Administrator. Such a 

job had been under discussion at REVLON and SHELDON suggested 

they needed to talk about the matter further. 

The proposed position of Public Relations Administrator 

was described as assisting with events, processing invoices and 

other budgetary matters, rallying the troops, and handling other 

miscellaneous duties. It was described as a junior level 

position. 
3669 

OIC-302a (Rev. 8-19-9-t) 

29D -OIC-LR-35063 

JENNIFER L. SHELDON 3/27/98 3 

Continuation of OIC-301 of .oll . Page - 

On Monday, January 12, 1998, SHELDON spoke again with 

SEIDMAN. SEIDMAN thought that an offer to LEWINSKY for the 

position of Public Relations Administrator should be pursued. 

SHELDON concluded that such was the final decision. When asked 

her opinion, SHELDON said LEWINSKY was "fine" for the job. 

On Tuesday, January 13, 1998, SHELDON telephoned 

LEWINSKY to formally offer her the job subject to a satisfactory 

check with her references. SHELDON said she needed to have her 

reference information, which was not in hand at that time. 

LEWINSKY facsimiled the reference information by the end of the 

business day. LEWINSKY was not employed at the time and 

therefore, there was not a two week notice period in which to 

handle some details such as checking references. 

SHELDON recalled that she contacted the references 

either the same day or the next. LEWINSKY's references were not 

available and not due back until January 23, 1998, so there was a 

potential delay in the processing. 

SHELDON said that under normal circumstances, at least 

one reference, provided by the applicant, would have been checked 

by the time a formal offer was extended. The handling of this 

candidate was faster than normal. SHELDON offered the example of 

another hire by REVLON, NANCY MIRANDA, which was handled 

expeditiously. 

SHELDON and SEIDMAN had a discussion of the salary 

which should accompany the offer of employment. They looked at 

her previous salary and the range of compensation for the 

position under consideration. They came up with the figure of 

$40,000.00 as the salary to offer. 

After notifying LEWINSKY of the formal offer, SHELDON 

called SEIDMAN to advise her the call had been made. She did not 

discuss the matter with anyone else. There was no further talk 

about LEWINSKY until the story about her and the President was on 

the news. She had no further contact with LEWINSKY at any time 

thereafter. 
3670 
3671 

Jennifer Sheldon, 4/23/98 

OIC Deposition 

Page 1 to Page 36 

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: 202-514-8802 
3672 

0s Jennifer Sheldon. 4i23l96 xyIu1,1, 

Page 1 

[31__--______-_________x 

[4]IN RE: GRAhT _-TRY INVESTIGATION 

I61 

171 

[Bl DEPOSIIICN of JENNIFER SHELiX,N, held at the 

[gjofflces of nezsri. Stillman, Friedran L Shau, 425 

(lo]Park Avenue, S?ii York, New York 10022, on 

[il]ThUrSday, Ap~;l 23, 1998, comenc~ng at (12:50) 

[12] oclock ’ t-z., before Annette Forbes, a Certified 

[13]Shortha& (Stenotype) Reporter and Notary Public 

if.!4 within ac< for the State of New York. 

Page 4 

[II 

What we are goi 

i:; create as much as ossrble 

to try to do is 

[ 4 1 III front of the grancfjury. nqhe expenence Of being 

I51 [ 6]that. 

Let me explarn to you what I mean by 

(71 A Okay. 

Q The first thing you should know, in 

I89ia normal grand jury setting you would have the 

( 10 1 grand jurors here, and there would also be a court 

I 111 reporter who takes everything down, which the 

[ 12 1 court reporter is doin 

Page 2 

111 

r21APPEARANCES: 

(31 OFFICE OF THE INDEPENDENT COUNSEL 

1001 Penns lvania Avenue, N.W. 

I41 Suite 4dNotih 

Washqton. D.C. 20004 ,C, 

LZl 

BY: THOMAS l-l. BIENERT, JR., ESQ. 

!61 Associate lnde ndent Counsel 

STEPHEN BINHAPESQ. 

t;i 

Associate Independent Counsel 

[91 .^. 

lU1 

111 

121 

131 

141 

151 

16; 

171 

i81 

191 

201 

2il 

221 

231 

241 

251 

Page 3 

r2lJENNlFER SHELDON,calledasa 

[31 witness, having been first duly sworn by 

I41 Annette Forbes, a Notary Public of the 

151 State of New York, was examined and 

testified as follows: 

t7”; DIRECT U(AMINAT~~N 

101 BY MR. BINHAK: .-1 

Q Good momin Let me just ask you 

[ :,i ‘ to state your name and s llgii for the record. 

A 

;::;S-he-Id-o-n. 

Jennifer S fi? eldon, J+n-n-&f-e-r 

Q Ms. Sheldon, my name is Steve 

i :: i Binhak. This is Tom Bienert, Jr. We are 

( I 5 1 associate independent counsels. We are hel ing a 

116 1 grand jury which is sitting in Washrngtcn. 0. . 

~17]conductan r~ves$ationofpossrblevrolabo~of 

118 1 Federal law, ind ing obstruction of ~ustrce, 

119 1 perjury and subornation of pe ury. ‘

I201 Do you understand 1 hat? 

[21] A Yes. 

Q You are here today as an 

I:G i accommodation in lieu of having you come down and 

[241appear before the grand jury and disrupting your 

rzslday, we are having you here to have a deposition. 

Page 5 

(11 

I 2 1 out and talk to your lawyer outside. 

131 

r41today? 

Do you have a lawyer with you here 

[51 A Yes. 

176;that is? 

0 For the record, could you state who 

LB1 A Charles Stillman. 

Q 

r:iioffrce, in fact? 

We are in Charles Stillmans ’ law 

1111 A Yes. 

Q As I told you, everything you are 

I::isaying is being taken down by the court reporter 

r14land we will read that to the orand iurv. 

i15; As you ma 

( 16 1 deposition you woul dy 

know: in a civil 

~171 transcri 

get a copy of your 

[ 18 1 it, adop P,* 

t you get it, read it. you sign off on 

t1gltranscri 

It. You will not get a copy of the 

[ 20 1 rules o P 

t today. Thats ’ n conjunctron wdh the 

grand JU 

[211 A 

secrecy. 

Q 

%uld you explain? 

~::~secrecy. The bottom line is that 

There are rufes oarand jury 

r. Brenert 

[ 24 1 m self and the court reporter, we are going io 

[251a J opt those rules as though you are in the grand 

Page 6 

111 

rzljury, even thou 

Wha P 

h you are not. 

that really boik down to is we 

I: i cant ’ go out and tell anybody about what you say 

15 1 in your testimony, and we wont ’ do that. 

You on the other hand am not 

17”; subect ’ to any rules ‘ of secrecy arid 

hod d 

ou can tell 

y you want what you said t ay thats ’ your 

iii &ess something you may want to ialk about or 

[ 10 1 discuss with your lawyer. 

[ 11 Iwhat you want. 

Make your decision, do 

OlCSmr Page 1 to Page 6 
3673 

BSA --. 

Page 7 

Jennifer Sheldon, 4/23./98 XMAXIMI 

Page 10 

L?; 

: 2 ! a trial at some time for some reason as a resutt 

I 3 1 pf this investi ation. 

[ 4 j KS possible 

If that were the case, 

t t! at some of or all of your 

[ 5 I testimony could become part of the record of that 

[sjtriat. 

17: Do vou understand that? iai A Okay. ‘

riagilndy 

Q In addition, the Oftice of 

[ 11: fun 

ndent Counsel has two types of report&g 

tons. At the end of the investigation, the 

[ 12 lOftice of Independent Counsel is required to 

I 13 I submit a report of what it has done. tts ’

I 14 lconceivable that some of your testimony may appear 

rl5lin that reoort. 

i161 ’ Do you understand that? 

[I71 A -Yes. 

Q Also under a limited circumstance 

1: “, i the Office of Indeoehdent Counsel can be reouired 

i 2 o j to report to Congiess,, Fake a, report to Congiws. 

122lall of 

:2;;ziwere the case, tisposs~pie that spme or 

our testrmony wou d be lnduded In that 

2 

124; Do you understand that? 

[251 A Yes. 

Page 8 

[I! 

[Z! Q 

:3j!he 

Pretty much the last exception to 

rand jury secrecy is that Mr. Bienert and I 

[4jWOR wtth certain people, FBI agents and other 

[ 5: attorneys. And those peo te, we often share 

[ 6 1 information from the gran s, jury with other people 

[ 7 1 in our office ,so that they can condud their 

: a 1 responsibilibes as part of the Investgabon. 

And that s of course why the court 

: :,j ‘ reporter Ms. Forbe; is here tolisten ’ and record 

: 1: 1 the testhony. she serves a function. 

“2’ Also, any people that come in 

j 13 j contact with your testimony like Ms. Forbes are 

14 ‘ abound by the rule of grand [ury secfecy, so they 

j I 5 1 take on all of the responsibility that we have. 

16j 

'17; 

Do you understand that? 

A Yes. 

j:e: Q 

I 9: Amendment. 

Let me tell you about the Fii 

(2C: A Okay. 

Q You have the ri 

Ig:lquestion today if you feel that t 9, 

ht not to answer any 

e answer to the 

F 13 1 question may tend to incriminate ou 

124: Do you understand tha r ? 

in any way. 

125: A Yes. 

Page 9 

[9!SO. 

110: Also, if I ask you a question you 

[ 111 dont ’ understand tease tell me you dont ’

[ 121understand it, I WI t 

113lquestion that you u 

m best to give you a 

Do yoi!$ers!and eve&. 

ers and. Oka ? 

;::jtold you? 

tng I have 

A Yes, I do. 

[25: Do you understand that? 

(11 

7 

I;; 

A Yes, I do. 

0 Is there anythin,g that you dont ’

[ 4 1 understan: abouu,what I have just told you? 

[5! 

Q Do you understand all of our grand 

itijury rights and responsibilities as I have fV old 

IBlVOU? ._ 

I91 A Yes. 

[lOI Q Ms. Sheldon,, why dont ’ you tell us 

[I 1 Iwhere you work, what your lob title IS, what you 

r12ldo as Dart of vour iob tttle. a thumbnail sketch 

i13iof youi empldvmeirt. 

A _ I work at Revlon, the corporate 

I ::i headquarters at 658 Madison Avenue. My tile is 

r16lmanaaer of coroorate staffina. 

i17j - I am iesponsible f& recruiting, 

[ls]screening, hiring candidates into the o anization 

[ 19 1 or involved in the promotion process XmploTees 

r201who are already existing there for the corpora e 

~21 I headquarters, and I have been for six years. 

1221 Q As rrt pforqur job, have r ever 

123lheard about or me an In tvldual named onica 

r 2 4 1 Lewinskv? 

i25i _ A Yes. I have. 

Page 11 

[II 

Q 

i: 1 meet Monica Lewinskv? 

When did you first hear about or 

[41 A OnFtida Januarygth 

151 0 Is that l&8? 

161 . . A 1998. 

Q 

Iiior meet her? 

How did you hear about Ms. Lewinsky 

A I redved a phone call from Allyn 

[ :zi Seidman who is the senior vice president of 

[ 111 Corpora& Communications, Public Relations, and 

[ 12 I she had called me, advised me that she had a 

r13lcandidate who was, whether in the waiting room or 

r141in her office, Im ’ not sure, but she had a 

I is~candidate she wanted me to interview and that she 

I 16 Iwould send her upstairs in a matter of an hour or 

ll7jSO. 

Q 

~:~~Revlon. right? 

Ms. Seidman. she also works for 

[201 A Yes, she does. 

[211 Q When she called you on the phone, 

[zz]did she indicate to you that she had already 

I 23 1 interviewed Ms. Lewinsky? 

1241 A Not to my recollection. I ust ‘

[25 1 remember that there was an applicant t c ere and 

Page 12 

[ 2 when she was done with the Public Relations 

I 3 1 Department. that she would come upstairs to see 

r41me. 

[51 Q Did ou later learn that Ms. Seidman 

;;;actually in~rv$~lMss.Lewinsky before you? 

181 Q 

A 

Ho6 did you learn that? 

Allyn. through a conversation with 

r:ziAllyn Seidman. 

[::;before? 

Q Was that after your interview or 

[I31 A 

Q 

After my interview with Monica. 

As a general matter isnt ’ it true 

I :z 1 that normally for a lower level emplbyee a lower 

[i 61 ievel em loyee would usual interview it Revlon 

[ 17 1 Human c1 esources first and ?’ hen wouM move on to 

I 18 lthe department where they might be working? 

[191 A Usually. 

i:iiLewinsky 

[221 

,,” ~~;~;i~-;~~, Monica 

did ou do hat in your office? 

1231 Q Whbt wa; your 

124 iinterview with Monica Lewinsk 

oal in conducting at 

F 

What was the 

[ 25 I objective of your meeting with et? 

~___ 

Page 7 to Page 12 OlC-Stan 
3674 

By Jennifer Sheldon, 4J23/98 XMAX(yJ) 

Page 13 Page 16 

: : : 

.-. 

:-. A Really screeni 

r3!what her skilk were,,what she “3, 

her. understanding 

ad accomplished., 

; 4 iwhat her work expenences were and then assessmg 

:5!that for any existina needs. 

r6j 

[?!de 

Altyn had two positions in her 

9 

artrnent. would she be qualified to tfOKll 

!8:e er of those, enter either of those ro P s. 

Q 

: : ,’ i two positions were 

Do Lou happen to remember what those 

” ’ 1 A Sur& There was an administratiie 

,i; 1 assistant reportin directty to Allyn Seidman, 

13which was reallv 0 serve as her executive 

i 14 jassistant. _ 

P 

I151 Then there was q public.relations 

! 16lassistant who was .resplple for jumor level PR 

1 I7 :events. really working and in hand wtih the 

[ 18 Ipublic relations VP, but also providing 

ii gladministrative su oft. 

i20] Q &I that objectiie in mind, then 

i z 1 I YOU met Ms. Lewinskv? izzj- A Yes. _ 

[23] 0 

[24]met her? 

Did you have her resume before you 

!I?51 A No, its ’ at the same time. 

ill 

Page 14 

She was at the eighth floor 

iiireception area and the receptionist called and let 

[ 4 I me know she had completed her application. I went 

[s:out and got the a plication with her resume and 

[61Ms. Lewmsky at P he same time and I walked her 

f 7 1 into my office. 

Q Is it fair to say that you didnt ’

I zi know before Ms. Seidman called ou that you were 

lo!going to meet with Ms. Lewinsky r hat morning? 

Ii] A That is correct. 

121 Q Was that in the morning or 

;:3iaftemoon? 

A It was right on the fringe between 

~~:~12:00 and 12:30. So it was afternoon. I guess. 

[:6] Q Why dont ’ you describe how our 

:: 7 1 interview went with Ms. Lewinsky. what you I alked 

I IB j about, what your impressions were. 

::9’ A Okay. It was very cordial, very 

:zsjnice. I would say we probably had a very standard 

; 2 I 1 interview. I asked questions. she responded; she 

:z:~asked questions, I responded. 

We went in chronological order 

!i:; through her resume from her education into her 

i:s!work experiences aid all the way up to her present 

1.. 

[;I How Icn 

7, ‘

,-. A Fo 

Q 

rt? 

did the interview last? 

-five minutes. 

14! Is that about average? 

!J; A Yes. 

I” i you 

0 

spoke 

Did you speak to Ms. Seidman after 

to Monica Lewinsky for that 45 mmutes 

! B j and made the evaluation that you made? 

r4: 

110: 

Iii! 

A Yes. 

Q 

A ed Ms. Lewinskv to the 

[X i elevaton. said 

113;off%ze. I called A 

oodbye to her, went back-into my 

rl-l!map&ed 

lyn. Just to let her know I had 

ri5;and 

up. had escorted Monica to the elevators 

lyn probably said what did you think, whats ’

r16iywr evaluation. 

i it: i for the two positions that were available t 

I explained to her my reasons 

E&he 

[ig:was not qualified. She did not have the skill set 

[zo~or an experienced ecough skill set for either 

~2llp0sitix at this 

[221 

[::;Monica 

Q ~?~~~,%%&;.other q-tin. 

During the in efview do ou know d 

Lewinsky mentioned agen ’ leman named Vernon 

[rs]Jordan? 

Page 17 

OlCStarr Page13toPagel8 

[II 

;;i 

A Yes, she did. 

Q 

[ 4 j Jordan was? 

Did you know at the time who Vernon 

A Yes. I am aware that he was on our 

[ 2 j board of directors. 

[7: Q 

A 

How did she bring u Vernon Jordan? 

[?: On the application tl!ere is a 

[ 9 I little box that you fill out how you were ‘ referred 

[ 1 o 1 to the o 

[ 1: j Jaymie 2 

anization. And Monica had written 

umans ’ name. 

[12: And I asked her how she had come 

[131 

P 

articularly te Mr. Durnan. She had said it was 

[ 14 ; hrough her interaction in Washington, that the 

[I 5: had come into contact with Mr. Jordan and that she 

[I 6! had ha pened to mention to him that she was very 

I 17 I mteres P ed m fashion,. the retail industry, and 

[ 18 I through that connectlon she got the Revlon 

[ I 5 1 intervtew. 

Q Let me flip now back again to where 

Isy&e were. Thats ’ where you just mentioned you had 

1:~ 1 a discussion with Ms. Seidman, you had given her 

[ 23) your evaluation that Ms. Lewinsky was not 

124 lappropnate for either of the two jobs open. 

125: What was Ms. Seidmans ’ response to 

Page 16 Page 18 

i’ ] 

.- 

[-Ijob. And we talked through ea$?h of thqse. 

i3: 

[‘Ii 2 %$I!% !?tt.~~$( ‘ %$nded ‘

!5!very well, she had good commumcabon q ilk, 

[6jseemed very, I don t want to, not energetic. but 

! 7: very happv, had a smile on her face. verv pleasant 

islto Speaktiith. ’

_. 

0 

::iievaluating 

You told us before that you were 

her against two positions, that was 

i 1 I 1 your objective. 

[::I What was your evaluation of Monica 

! 13 1 Lewinsky with respeit to each of those positiins? 

1143 A For each of those positions, it was 

I 15 I mv evaluation that she was not aualitied for 

i :6 jeifher. 

0 Is it fair to say that you thought 

i $ i she was a perfectly nice indrvidual might be 

[I 9 1 qualifti to work for the company, but at least as 

! zo 1 far as these two positions were concerned. she was 

;z I i not the right petion? 

;22! A That is correct. 

:23; Q Did you talk to Ms. Seidman after 

: I 4 1 you had that interview - well, let me go back one 

r25;step more. 

LA. 

[2 j that? 

[31 

14! 

A She was very understanding. 

I think that she listened to mv 

[ 5; evaluation and then she had proceeded to say. do 

[ 6 1 you remember our discussions about havi 

f: j administrator 

r‘” 

of personnel in our depa ?rE&t 

[gland that type o a role, that I have been sa 

[ sIthat I have needed for a while? What do you 9. Ink 

I I o I about Monica for that type of a job? 

[Ill Q 

A 

What was your response to that? 

ltspossible. ’ I needed to know 

I :: i more information about where she wanted to head 

[14 lwith the administratots ’ job, but it certainly was 

11518 possibil. 

% 

. 

1:76:terms of was it a 

HOW would you describe that job in 

unior ‘ level job, senior level 

[ I g i job, intenediate 4 

A A junior. Well the terminology I 

/:Og&ould use to describe it, it w&ld be a junior 

[z 11 level professional job. 

Q And that is sort of more toward on 

I:: i the starter end of an executive position? 

1241 A Yes, two to three years of 

r25!experience was fine. 
3675 

BSA 

_ 

Jennifer Sheldon, 4123138 xkANU4) 

Page 19 

1: 

,_)I Q Did you make a decision on that 

i; jduring that conversation with Ms. Seidman? 

i :i leave. 

A No. It was Friday. I wanted to 

So we finished the conversation. wrapped 

: 6 1 up and I went home. 

!I ‘ Cl Did 

I 9 1 about Monica and t !l 

ou talk to Ms. Seidman again 

at position? 

[91 A On the following Monday when we 

101 returned to the office, to work. 

Q 

G iconversation? 

What was the substance of that 

A We talked more about the 

:: iadministrator role what it would be how it would 

151seryice the deparbnent, more of th& details, what 

16]the substance behind the position would be, and if 

17 1 that were to be a position where it would fall 

161 into a ranking, because all sitions at Revkn 

191 are ranked by a grade, on t G professional side 

2 o 1 from a grade 1 to a 20, lets ’ say. And so each 

11 lgrade is ranked. 

221 So what we had to do was figure out 

231 by the skill set that was bein required to 

z .I 1 perform the job where it wou 9 d fit Into a ranking 

25lsystem. 

Page 22 

[:: 

(2: A Right. 

i 3 Q So this was a reporting function 

i 4 isort of back to the mother ship, if you will? 

15; A Right. 

16: 0 As a result of that phone call, did 

[7:you all make a decision that da 

r 

? 

i9: A Yes. I rimarily stened in. It 

[ 9: was really Jaymie an 

[:c] Allyn toM J$m,e the d%&c?versation’ 

Allyn havi 

I 11 Iwhat her intentions were which was to offer the 

[12]position to Monica as ublic relations 

1131administrator at $40. OE 0, to start as soon as 

[ 14 J possible; as soon as she gave us the date to 

[151start. Mr. Duman concurred and told us. I went 

[lslahead. 

[171 Q In the grand scheme of things, would 

[ 19 1 ou sa that this was a relatively quidc movement 

rlsl&rougithe hiring process? 

A In totality of how bng positions 

fgy;nomIally stay o 

Q 

n yes. This was pretty fast. 

[221 616 actually communicated the hiring 

r23:decision or the offer. as it were. to Ms. 

i 2 4 j Lewinsky? 

1251 A That would be me. I did. 

Page 20 

:11 

[21 Q Does that ranking system exist 

[ 3 1 primarily because you need to set compensation 

I 4 I rates? 

isi A 

I 6 I ranks, it allows 

Its ’ compensation, its ’ skill set 

Q 

ople to have career paths yes. 

EIJ did that for this job be&se it 

ii iwas not actually a .ob that actually existed at I, [slthe company, right.. 

A I needed to have some sense of 

:i j foundation before I could sa 

12 1 it. what do we call it, and o ffy 

how much to pay for 

i3ltltle. 

iclally give it a 

0 Now as a result of this second :z iconversation with Ms. ’ Seidman did 

16 1 understanding that you would oher 

ou come to an 

J 

17la job? 

onica Lewinsky 

19: A I dont ’ believe we came to that 

I g]final understanding until Tuesday. 

0 And how did that ultimate decision 

iyicorne to be? Did Ms. Seidman say we want this 

zz 1 position and we want Monica Lewmsky to fill it or 

23 1 was it a conversation, how did that come about? 

141 A 

:5 1 terms, but 

I couldnt ’ say it exactly in those 

I think that once we had put a 

Page 21 

: I 7 1 Forbes is a holding company, corred? 

!I91 A That is correct. 

iZicorrect? 

0 One of its holdings is Revlon, 

i2lj A 

1211 0 

One of them, yes. 

Thats ’ where you work, at Revlon? 

:231 A Yes. 

Q Jaymie Duman is a gentleman who 

~~~iworks at MacAndrews 8 Forbes? 

Page 23 

[Ii 

121 Q How did oudothat? 

[31 A Via the te 7 ephone. 

141 Q 

A 

What did you tell bet? 

I asked for Monica and I identified 

~~~myself. I told her that I had 

17 1 would like to offer her a pos ip 

ood news that we 

ran at Rev/on. 

[El I went through the tile, the 

[ 91 relations administrator, the salary, $4 8 

ublic 

$00. We 

[ lolwould like ou to start as soon as sslble. But 

r?llas part oft t e hinng ” process, we a i!? o needed 

[ 1: J reference checking, so if she could send me 

[ 13 I references. 

I141 And she probably ask* me a question 

[ 15 1 or 90 about the compan$dust IJte yhat are the 

[16]starttng hours. And she I ask me IS there any 

[ 17 1 way she could do more research on the company. 

Ii91 I ave her our Internet address and 

[ 191told her tha P 

[zolcettain 

r 

once she got here, she would have 

access to the annual report, which is 

[21]also ou on the web site, as well. 

~::;dleck? 

Q Did she give you some references to 

A Yes she did. She faxed them to me 

I:“5ithat day. She fax& over two direct references 

Page 24 

12 Ithat I could call. And after she had given them 

[31to me, I did place a phone call to them. but both 

I 4 I of them were out of town. 

I didnt ’ leave messages because it 

izlwas over a weeks ’ worth of time until the were 

17 1 retumin 

[ 3 1 later da a 

So I put it aside to call them a r a 

e and time. 

Q Isitfairtosa ifthose 

[ :ii references worked out, she x ad been offered a job 

[I I I and she understood that if they came back with 

[ 12 1 acceptable references, she was going to get the 

[13ljob? 

A 

I:zibut I guess. 

I dont ’ know what she was thinking, 

Q 

i:;jcommunicate? 

Is that what you tried to 

iI81 A Yes. Thatswhat ’ I tried to 

[ 13 1 communicate es. 

If Fitime that 

Q ’ bd anything happen in between the 

ou had this conversatton with her and 

[zzlthe time t at ou got the references? 

iziiwithdraw that question, ask ou another question. 

[251 

Or ‘ !et me put it thi; way. Let me 

Did you ever get t e references from 

Page 19 to Page 24 OlCStarr 
3676 

mA Jennifer Sheldon, 412396 XMAX(Y5) 

Page 25 

-:!her? 

A I got the faxed reference list, but 

.: i I never spoke to either of the references on the 

:s:list. 

i -_ Q Why not? 

._. A In my best understandin it would 

: 3 j be that a story was communicated via t R e media 

.s! that Ms. Lewinskv was involved in a White House 

:!::matter. 

_--. Q And as a result of that media story, 

: :z :did someone at either Revlon or MacAndrews 8 

: 13 I Forbes give ou directions on what to do with the 

: :; 1 applicatron &onica Lewinskys ’ application? _-i. 

.--_ A 

:;;!beyond me. 

No. It was handled by authorities 

Q Were you ever told not to pursue 

i 1 i i getting references for her? 

--i. .--. A No. All of my files had been taken, 

:I:: so I wouldnt ’ have had access to them. 

.--> Q So you came to understand that for 

:X ~whatever reason you were not to continue on this 

: I 3 1 project? 

e-4, 

.- . A That is correct. .^_. .-31 MR. BINHAK: I have no 

.’ 1 

Page 28 

' in 1 when would the interview process have begun with 

I 3 1 Ms. Lewis, when would the offer have been made and 

! 4 Iwhen did she start? 

[jj can you repeat that? 

L61 A Q Imsor39 When ’ Id the Interview process with 

I 7 I Ms. Lewis begin the one that ted to her winding 

; B I up getting this Pk administrator3 job? 

::iiso we 

A We intemalty posted the position 

had quite a few internal people apply. Ms. 

: 11 ILewis is an Internal employee who was transferred. 

; 12 ISo we had, to my best recollection, three internal 

: 13 Iemployees interview, four applied, but one was not 

:i4lqU&fkd. 

::51 Q 

; i 61 Revlon for 

SO Ms. Lewis had been working for 

some time? 

::71 A Yes. 

il81 Q When wou# the position have been 

~191 posted, roughly? 

!201 A If not the last week of February, 

rzllthe first week of March. Probably February. 

[22] 

:23 1 March, th;pos%%T%%$ tjIj”’ eany 

[24] 

[251 Q Then afler the five-day dosure of 

Page 26 

_-, 

._. 

.-, 

-31 

further uestions. Mr. Bienert may. 

BY JR. BIENERT: 

:;: Q Just to follow up on the references, 

: 5 : is it accurate that at least 

: 6 1 have done one reference %eck before extending an 

ptcally ou would 

.-; offer? 

:a: 

:I; A You try to. Sure, yes. 

3 Q 

: : 3 : start date? 

Did you talk to her about a possible 

. . 

_--, A Yes, I did. ..^. 

.--_ Q Did it sound about ri ht that the 

: 12: start date discussed with her would 9, ave been 

: : 4 I around the 26th of Janua ? .-=/ 

_--. A It sounds a % out nght, yes, if my 

: : 5 : recollection is correct. 

Q Whatever date it was, that da 

: r r‘ jsome other, would you have communicated XI 

or 

at to 

: L 3: Ms. Seidman? 

_--_ A Yes, I did. And because at that 

: r: : point in time it had not been completely 

: 1: :determined to whom she would have reported. 

.-:‘ _--. So it was absolutely the most direct 

: I: ) way to let the Public Relations Department know 

I 2 : she had accepted. she will be starting. 

Page 29 

!I1 

[2 1 the postin you began the interview recess? 

[31 % Wtih those internals w ! 

L 4 I the positioa yes. 

o applied for 

151 Approximately how Ion3 after 

(61 interviewin Ms. ewes was an offer e ended? 

I71 

w 

I would say between that time, it 

I a 1 was probably about a month. 

!91 Q 

::oljob? 

And then I assume she accepted the 

:111 A Yes. She formall accepted. 

!l?I Q And started sho rx 

A 

y thereafter? 

Wtihin probably about a week and a 

ii:; half to two weeks switchover leaving her 

!:51department and comin to the new one. 

L161 Q When rs1 s. Lewis and the other 

:171candidate for this job first interviewed did they 

: 18 Iinterview with you or someone in the human 

: I 9 1 Resources Department first? 

I201 A A separate recruiter was involved in 

:z~lthis process. So I would not be able to answer 

:zz 1 that question. 

:231 Q When you say a separate recruiter, 

:24 1 what do vou mean? 

i25j * A A different person who reports to me 

Page 27 

_-_ 

i < j What she 

I 

i! 

ave that information to Allyn. 

c oose to do with it or to whomever she 

; 1 was going to be working. 

.E. 

.-. Q 

: I: she would 

I take it while you dont ’ know if 

report to Allyn Seidman,. it was your 

: - : understanding she would be reporhng to somebody 

: s lwithin Allyns ’ de artment? 

- 

.:: ‘

A Af&olutely. 

.--_ Q 

: 1: : administrator? 

The name of her job was PR 

,._. 

.--_ A Yes. 

.. _--. i‘ Q Has that position been filled? 

:::: A Yes, it has. 

___. Q What is the name of that person who 

i !! j now has the job? 

._ ,_ .-_I_ A Tracy Lewis. ._i. 

_--_ Q As best you can tell us date wise, 

olcstarr 

:11 

Page 30 

!21was the point person. 

Q But someone within the Human 

iii Resources Section? 

!51 A Yes. 

!61 Q And then would Ms. Lewis thereafter 

; 7 1 have been interviewed with people like Ms. Seidman 

1 a 1 and othemAwtth+tthe Communlcabons Department? 

191 

.d‘ 

:101 But, a%~. I car0 verify tithe 

: I I 1 recruiter was firs 9 or second in the interview 

i 12 I slate, because I have not been the one doing it. 

:131 Q Is that sort of the normal 

! 14 j procedure? 

A Wtih internal employees its ’ a 

i : 2 ; little bit more varied, only because 

: 17 I know the internal employee, you WI I ‘ I say you 

ou might ‘

0 

I: a 1 rntennew with this executive, I will wrap up wrt 3l 

[lglyou. I follow u 

Lzolare alread 

with an interview because they 

!50 [stead of meeting them up front 

a nown entity within the work force. 

:211 

::zlletting them meet the department and wrap ing 

:z3lyou would a lot of times, you end up doing P he 

up, 

:24lwrapup. 

i251 0 Having them meet the department 

Page 25 to Page 30 
0% 

3677 

Jennifer Sheldon, 4t2398 XMAXlUb) 

Page 31 

1:‘ 

I -. first then? .- -~ - 

!3: A Then come to you. So with an 

[a.rntemal emplo ee. ls hard to sa there is a 

;;;Ef;;hat rt 4 s R first. then the lI epartment 

.=. 

(“ Q Who was it who directed you, if 

[B anyone, ‘ to go ahead and post that position? 

i3: A Allyn, m senior vice president of 

r:~Hurnan ‘ Resources, a rKl 

Q 

also our Legal De artmerit. 

. And who in particular woul 

I : ! f been the people? 

s have 

A Allyn. Ron Dunbar, who is senior 

i::ivras president. and Chip Nichols, who is our 

r~s:general counsel, all confirmed that it was okay to 

[ ~~:go ahead and job post the position. And they so 

[I-:advised me to do IL 

Q How typical is it that the Le 

I: i i Department is conferrmg with you about w a 

al 

ether to 

12o:mst a position? 

1::: A Sometimes we get into discussions 

[x:about that with the Legal Department. 

We particularly go to them for 

~:Ziguidance, parbcularty the employment law group, 

r~5:particularty in a case if you have, say, a 

Page 32 

[ 2 : reduction of work force and all of a sudden you 

[ 2 : have to post a position in this department that 

14:just had a huge reduction. So they advise and 

~5: counsel us. 

[E: Sometimes if someone is let go under 

~::maybe bad circumstances and that you are going to 

; ;;gt therr posrhoqn.~ look to the Law% 

partment for u ante on those thtn s. 

[I:: So in he past they certainly ave 

I 1: -counseled us on the ramifications of posting or 

i 1: j not postin a position. 

_ 

h ‘ Was this position, the PR 

1 :i ladministrative position. had there been any kind 

[ 15. of raductio/ in t:. work force? 

[Ii: 

I*-. Q So was it in reaard to this 

i ; 9 i position? 

A No. No. There are times when you 

iliido use the Legal Department for advising counsel 

rz::on job posting. 

[?:: Q And there would be times when 

[ 2 3 : because of some other factor, some reduction in 

[ 2 4 : the work force, its ’ your view, view of 

p” 

ople in 

[zj;the department involved that the lega personnel 

Page 33 

11; 

[ 2 : should wei 

B 

h it? 

[3: Yes. 

14: MR. BIENERT: Thats ’ all. 

15‘ MR. BINHAK: One auick 

I;; question. 

BY MR. BINHAK: 

Q Is it the policy of Revlon to file 

::jopenings from within, wtth internal hires? 

A It is the preference that we would 

t:yjfill the position from an internal employee first, 

[ 12 : before goin 

c? 

to the outside. 

So thats ’ why you posted this job 

~::~intemally first right? 

[15! You have to say yes or no for the 

[16:ECOd. 

_ _ 

[Ii! A 

~:89&is job? 

Q 

Could you repeat that question? 

Is that the reason why you posted 

[zo: 

[21! $ ?!r%o%%r%a%!~ob. 

[2?: After Monica Lewinsky was out of the 

[ 2 3 : picture. then you ted 

12 4 !os : company, correct. 

that job inside, to the 

[25: A Yes. 

Page 34 

r.. 

,-. 

1:: Q 

I 3 : general policy? 

Thcts ’ in accordance with your 

(4: A Yes. 

:5:to be filled. 

Because the position was going 

[E’ Q 

: 7 j an internal 

And then because you filled it with 

Frson. 

[ B ; advertised 

that job was never externally 

i4; A Never advertised, never sought an 

!:s:extemal candidate for it, right. 

Ill: MR. BINHAK: I have no further 

Ill; questions. 

,7 7‘ 

,--. MR. BIENERT: Thanks a lot. 

Cl41 (Whereupon,, at 1:15 oclock ’

[:5: pm.. the deposttion was concluded.) 

i1i: 

1171 

I191 

[13i 

120: 

121: 

[221 

[23! 

[24! 

125; 

Page 35 

CERTIFICATE 

i: i STATE OF NEW YORK ) 

$O”NT-& NEWYORK) 

:51 

[6! I. ANNETTE FORBES, a Certified 

[7] 

18: Notary Pudic of the Slate of New 

Shorthand Stenotype Reporter and 

!91 York, do hereby certify that the 

r* . 

;;;i 

for oin Deposition of the witness 

IlZi 

JE%IFf!R SHELDON taken at thetime ’

i131 

and place aforesaid, isa ’ true and 

i141 

:oE transcnphon of my shorthand 

Cl51 I further cert’ 

s 

that I am 

[161 neither counsel or nor related to any 

[:71 party to said action, nor in any wise 

119i interested in the result or outcome 

i191 

[201 

[21] 

1221 

I231 

thereof. 

IN WlTNESS WHEREOF, I have 

hereunto set my hand this 29th day of 

April, 1998. 

124: 

I25: R 

Page 36 

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13: 

[4i 

[5; 

(61 

[7: 

[ei 

[91 

ilO! 

Cl11 

[12:. 

1131 

i14i 

I151 

116! 

1171 

iiei 

1191 

[ZOI 

[211 

122: 

(231 

I24! 

:251 

Page 31 to Page 36 OlCStafT 
3678 

i 
3679 

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

- 1 - 

OFFICE OF THE INDEPEhBENT COLlVSEL 

Da:e of rranscnptlon 4/20/98 

FLOYD SPARKS, JR., Computer Consultant, sub-contractor 

from BOOZE, ALLEN, & HAMILTON, INC., and assigned to the Office 

of Information Resource Management (IRM), U.S. Department of 

Defense, was interviewed in the offices of the Pentagon General 

Counsel, on March 9, 1998. Also present was Ms. IVEY MARTINS, 

Corporate Counsel, from BOOZ, ALLEN, & HAMILTON, INC., 

8283 Greensboro Drive, McLean, Virginia, and Deputy General 

Counsel for the Pentagon, BRADLEY WEIGMANN. Representing the 

Office of the Independent Counsel were Special Agents (SAs) 

Federal Bureau of 

Investigation (FBI), and JIM RICKARDS, Computer Support, OIC. . 

After a brief explanation of the purpose of the 

interview, SPARKS advised that MONICA S. LEWINSKY had requested 

his assistance on how to erase certain files and e-mail messages 

from her desk computer located just outside the Office of the 

Secretary of Defense for Public Affairs, KENNETH BACON. This 

request came approximately one week prior to her resignation, 

because he had already been notified of her pending departure. 

He was not approached personally by LEWINSKY, but was assiqned to 

assist her after she contacted the IRM help line. 

she acted excited and agitated 

When they met, 

information and pressed SPARKS 

about her concerns in erasing 

for instructions. 

LEWINSKY told SPARKS that, based on discussions she 

had with LINDA TRIPP, LEWINSKY understood that deleted files and 

e-mail from her computer could still be retrieved later, unless 

erased. LEWINSKY was concerned that other employees who 

occasionally_utilized her computer could retrigve and read her 

personal communications. She was-specifically concerned about ’ 

e-mail she had sent, more than ones she may have received. 

SPARKS instructed LEWINSKY on how to erase her e-mails 

in a brief meeting just outside her office. He explained that 

e-mail messages received or sent, which were deleted the same 

day, did not get automatically backed up in the Pentagon's backup system. All other messages were recorded and saved for four 

weeks on a rotational schedule at an off-site facility. This was 

done to maintain the integrity of-the computer files in case of a 

Investigation on 3/09/98 af Washington, D.C. File I 29D-OIC-LR-35063 

Date dictated 4/20/98 
3680 

OIC-302a (Rev. S-:9-94) 

233-OIC-LR-35063 

Continuation of OK-302 of FLOYD SPARKS, JR. .On 3/09/'98 .pape 2 

national emergency. After four weeks, tapes were rotated back 

and used over again to record communications. Once new 

information was recorded over the backed up information, the old 

information was written over. 

procedures 

SPARKS advised that once he carefully explained the 

to LEWINSKY she returned to her desk. He never 

physically went to her computer, 

LEWINSKY for further assistance. 

and he was never re-contacted by 

SPARKS believed 

that he had solved her paroblem. 

In his opinion, 

knowledge, 

He also had no information, or 

that any other IRM computer specialists were ever 

enlisted by LEWINSKY to provide further assistance. 

According to SPARKS, his boss, BONNIE NICHOLSON, had 

instructed IRM employees that it was a department policy to 

provide instruction, but not actually perform operations for 

employees seeking advise. Additionally, there was a policy that 

IRM employees were forbidden from entering an employee's personal 

computer to delete files. However, IRM did issue bulletins 

encouraging employees to occasionally erase old temporary, cache, 

and e-mail files in order to make space on the hard drive which 

had a finite capacity. 

SPARKS advised that neither he nor his IRM associates 

were provided the computer software tools such as "utilities," 

which could permanently erase information from a hard drive. He 

also advised that he had no software to perform image processing 

of a hard drive. 

a 

MS .- IVEY MARTINS, the B60Z, ALLEN, & HAMILTON, INC. 

attorney, representing SPARKS and their employer requested any 

further contact with her client be channeled through her office. 

Thereafter, SPARKS provided a home address of*'-'_r'- 
3 1 

. l”. U.-Y -au, 1 *““--Y6” _._--- - -=- ~ ‘ -, ---, - XL-70 

Page mlTeD STATE5 DISTRi‘COURT T IDR 7HT DISZRIC7 OF COLUHB1A 1 PROCEEDINGS 

______----------I 2 Whereupon, 

In IX?: 3 FLOYD SPARKS. JR. 

GRAND JURY -~YGs 4 was called as a witness and, after having been duly sworn by 

__________------~ 5 the Foreperson of the Grand Jury, was examined and testifim 

Crmd Jury Room HO. 3 6 as follows: unit.* st.te, Di,crlct COYIX r0T rhe DlIr.CiC~ Of colunbla 7 EXAMINATION 3rd ‘ Conrtitucion, H.W. 

wa,tlinqtcn, D.C. 20001 8 BY MR. BINHAK: 

rw2sd.y. n.y 12. 1998 9 Q Would you state your full name and spell it for tl 

rhc te,rinony Of FLLXD SPARK5, JR. Y*S L.kCIl In mc 10 record, please? 

pra*enc* ot l full quc.nn et Grand Jury 97-2, Imprneled on 11 A Floyd, F-l-o-y-d, Sparks, S-p-a-r-k-s, Jr., J-r. 

%?ptemLmr 19.1997. CcenenCinq .r ,2:05 p.m., c-?rore: 12 Q Good morning, Mr. Sparks. How are you today? 

so- I.. YISE_RC 

Lmp&yxnd&pmdene counsa1 

13 A Fine, thank you. 

14 SlMLu BIYHM Q My name is Stephen Binhak. I’m an Associate 

lu- TRA- Jlnxl -UN 15 Independent Counsel. I work at the. Office of Independent 

AS,ocI.ZC m*cpen*ant coun¶*l 

ott*ce or 1ndq.nd.ent couns*1 16 bmse~. 

1001 PmuSylvml~ ~“.I)“C, Ya=ZhYsSt 

Sultr ‘90 “OZth 17 This is Misha Travers, this is Julie Corcoran, Jim 

“.,hinqLlXI, D.C. 20004 

18 Crane and Sol Wise&erg. They are all also Associate 

19 Independent Counsels and they work at the Independen 

20 Counsel’s office. 

21 This is the grand jury and this is the court 

22 reporter and this is the foreperson of the grand jury whc 

23 just swore you in. Okay? 

24 A Okay. 

25 Q Before we start with this examination, I just want 

Pdqe 2 Page 1 

CO*rENZS I to give you a background on some of the rights and 

2 responsibilities you have as a witness before the grand jury 

P.g. 3 and I’Il ask you to give a verbal response to alI the 

4 questions and keep your voice up because the court reporter 

3 5 is taking down everything that’s being said today. Do you 

6 understand that? 

35 

7 AYeS. * 

8 Q AU right. This is a grand jury impaneled by 

9 United States district judge here in the District of Columbia 

10 and the grand jury is conducting an investigation of possible 

11 violations of federal law, including perjury, obstruction of 

12 justice and subornation of perjury. 

13 The Independent Counsel has authorization to 

14 investigate these acts by a grant of jurisdiction by a 

15 special division of the court, the United States Court of 

16 Appeals. Do you understand that? 

17 A Yes. 

18 Q The fmt thing I want to make sure you understan 

19 is that you have a right against self-incrimination. It’s 

20 your Filth Amendment right. You do not have.to answer any 

21 question today if a truthful answer may tend to incriminate 

22 you. Do you understand that?_ 

23 A Yes. 

24 Q Anything that you do say could be used against you 

25 in any kind of legal proceeding down the road and that’s why 
3682 

In rc: Grand Jurv Procccdines 

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1 that we can’t go out and reveal to anybody what you said 

2 inside this room. There are certain exceptions to that. 

3 The fmt exception is that there are people that 

4 we work with who help us with the investigation. We’re 

5 entitled to share what you say with them so that we can 

6 further the goals of the investigation, but anybody who gets 

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information like that, an FBI agent or a pamkgd or another 

attorney in our off&, is also bound by tbe rules of grand 

jury secrecy. Do you understand that? 

A ye.% 

Q The second exception is that some of the things 

that you say here could be used at a later proceeding or 

trial under certain cireumstanees, either to cross-examine 

you or as substantive evidence in a ease. Do you understand 

that? 

A yes. 

Q The third exception is that the Office of 

Independent Counsel has a reporting function. We have to 

prepare a final report and we under some certain 

circumstances have to issue a report to Congress. Some of 

what you say here today may be contained in portions of that 

report. Do you understand that? 

A Yes. 

Q You, on the other hand, are not bound by any of the 

grand jury sxreey laws. You can tell anybody anything abou 

Mult i-1 

Page 5 

you have that Fifth Amendment tight. Do you understand that? 

A Yes. 

Q If you’ve got a lawyer that you’ve retained for the 

purpose of this proceeding, you may feel free to go out and 

consult with that lawyer, but the lawyer cannot be with YOU 

inside of this room. Do you understand that? 

A Yes. 

Q Please tell me if you would like to go speak to 

your counsel at any point. 

A Okay. 

Q For the record, do you have a lawyer that’s 

representing you? 

A Yes. 

Q And could you give the grand jury the name of that 

lawyer? 

A Ivy Martin. 

Q Could you spell that please? 

A I-v-y M-a-r-t-i-n. 

Q Are you involved in any kind of agreement to share 

your testimony today with any other person or entity? 

A No. 

Q Let me tell you a bit about grand jury secrecy. 

All the people that I’ve identified as working with the 

Offkx of Independent Counsel and the grand jurors as well, 

we’re bound by the laws of grand jury secrecy. That means 

Page 6 

-r 

PageTM Floyd Sparks, Jr., 5-12-98 

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what you said here today. DO you understand that” 

A Yes. 

Q All right. There’s three categories of people +c 

can appear before a grand jury. The first is a targer .4 

target is a person who is a putative defendant or am- who 

is likely to be charged in an indictment. You are nr: 3 

target. Do you understand that? 

A Yes. 

Q Do you also understand that no prosecutor in sly 

investigation can ever promise somebody that they will n?;er 

become a target? 

A Yes. 

Q Okay. The second kind of person is called a 

subject. That’s a person that the grand jury is inti%d 

in their conduct and it could be because there’s poss$le 

wrongdoing down to the fact that they’re just a person u% 

has knowledge about what the grand jury is investigating 

Do you understand that? 

A Yes. 

Q You are a subject in the broad sense. There’s a 

third type of person called a witness which is an informa! 

term that has come to encompass people who are simply 

witnesses. They’re subjects in the sense that they LX 

knowledge that the grand jury is interested about, but they 

have no involvement other than that they’re witnesses. A 

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perfect example would be tire teller in a bank that gets 

robbed. Do you m&r-stand that? 

A Yes. 

Q You are a witness. Do you un&rstand that? 

A Ye!L 

Q And you also Mderstand that no prosecutor in aq 

investigation eould%ver promise sorneMy that they’ll abq5 

beawitnessoralwaysbeasubjectorncveratargct. Ym 

understand that? 

A Yes. Couldyouclarifyoncemore,yousaidIama 

subject as well as a witness? 

Q Right AsIsaid,asubjectisaverybroadterm 

that includes everyone from a mere witness, like the tella 

inabankrobbcrywbojusthandedovutkmoncybeaxrx 

therewasaguninberfaaz_to someonewhothegrandjtq 

might think had some kind of involvement in the rohbety. a 

pasonwhomi$xbavcdrivcnsomamctlmamdthcgnmd~ 

is not sure whether this driver was part of the robbq 01 

just didn’t know qd just drove someone there. So it’s a 

very wide range of conduct Do you understand thar? 

A Ye.% 

Q Andthat’swhymbavtasu-~oryofwitncssto 

give you a better understanding of where you fit within 

subject. Do you understand that? 

A Yes. 
3683 

In rtx Grand Jury Proceedings MUI 

Page ! 

1 Q Okay. So you understand that you’re a witness? 

2 A Yes. 

3 Q Okay. You’llt here because you reozived a subpoena. 

4 Is that correct? 

S A Yes. 

6 Q And I don’t believe that the subpoena called for 

7 any documents. Is that correct? 

8 A Yes. Correct. 

9 Q Okay. So you didn’t bring any documents with you. 

1 0 A I did not. 

1 1 Q Now, you have to understand that you can’t lie to 

1 2 us hen5 today. If you knowingly tell something that’s not 

1 3 trueormisstatesomethinganditturnsoutrobeamaterial 

1 4 fact, then that is a crime, it’s a violation of the perjury 

I 5 statute which is punishable by up to five years in jail and a 

1 6 $250,000 fine. It’s a felony. Do you understand that? 

1 7 A Yes. 

1 8 Q Is there anything that I’ve just explained to you 

1 9 that you don’t understand or you’d like me to explain again? 

2 0 A No. 

2 1 Q If there’s any question that I ask that you’d like 

2 2 me to make more clear, please ask me and 1’11 ask it again. 

2 3 And, again, I’ll remind you that if you’d like to speak tc 

2 4 your attorney at any time, please tell me and I’ll let you go 

2 5 out right away. Do you understand that? 

Page 1C 

I Yes. 

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All right. With all that said, let’s begin. 

Mr. Sparks, where do you work? 

I work for Booz-Allen & Hamilton. 

And what is your job title rhere? 

/ I am an associate. 

And what an: the general duties of an associate? 

Supervisory task management duties as well as 

I technical expertise on specific contracts. 

1 Are you working on a specific contract now? 

1 Yes. 

1 How‘ long have you been with Booz-Allen? 

1 Four and a half years. 

1 Okay. And what‘s your specific contract right now? 

1 My specific contract is with the Office of the 

1 

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Assistant Secretary of Defense for Public Affairs in the IRAM 

shop. 

Q Okay. Is that at the Pentagon? 

A Yes. 

Q Let me fist ask you, what’s your general 

backgroynd, your educational background? 

A High school graduate, college graduate. 

Q What was your major in college? 

A Management information systems. 

Q Does that have to do with computers? 

Page” Floyd Sparks, Jr., 5-12-98 

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A 

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Yes. 

Page 11 

Why don’t you just very briefly explain what that 

Management information systems? 

Yes. 

It’s information systems or using information 

systems to support conducting and handling computer 

technology. 

Q Now, you just said that you have this current 

contract over at the Pentagon. Why don’t you tell the grand 

jurors what your assignment is as part of tbat contract and 

also what the general contract is for? 

A My responsibilities on the contract include task 

management of four other individuals who also work fo 

Booz-Allen. We provide network, workstation, software, 

hardware support to the Public Affairs. 

Q Okay. When you say software and hardware, you 

talking about computer software and computer hardware, 

correct? 

A Yes. Operating systems as well as support 

utilities such as Microsofr Offw, Word, Powerpoint, Exel, 

things of that sort. 

Q All right. Now, when you say support, I want to 

just discuss with you exactly what that means. Is it fair to 

say that when people have questions or problems with theii 

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Page 12 

particular computer or the software that’s running on it, 

tbFYE8ncoMtOvBMUSmcmbdSofyourgroupandasktbcm 

questions and then people in your group will vd, give 

them advice about how to deal with those problems? 

A Yes. 

Q Do you ever actually go to people’s workstations 

and do the worE for them? 

A We assist them in doing their work. If it’s 

somdmdy who nads help with Word or Pomxpoint or anything 

else, we assist them in getting started, We do not do the 

work for them. 

Q All right. What’s a typical kind of question that 

you might get or a request that you might get fro-m an 

employee? 

A Creating a Word template for memos. Helping them 

send tmail to individuals outside the Pentagon whae an OMIT. 

or Internet ad& is needed. Installing software that they 

need since they cannot install software themselves. 

Q All right. So in the case of someone who wanted to 

set up a template for a memo, they would ask you how to do 

it, you would give them instructions and then typically wbuld 

they go back to their computer_perforrn the operation? 

A Yes. And other times we will create the template, 

depending on the complexity. 

Q Ail right. And as far as instaliing software, you 
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said that only people from your group install software? 

A COITeCt. 

Q So a normal employee at the Pentagon just can’t put 

up, say, a spreadsheet or some kind of program on their 

machine? 

A A spreadsheet is part of Microsoft Exel, so we 

don’t keep them from creating documents. We have a policy 

whacks they cannot go and buy a copy of Sidekick and load it 

on their machines. 

Q Okay. What kind of computers do the employees at 

the Pentagon in your area where you work, what do they have 

A They have IBM Pentium PCs. 

Q So that’s a standalone computer on each person’s 

desk? 

A Correct. 

Q Is that connected to a network? 

A Yes. 

Q Why don’t you briefly describe how that all works? 

A How the PC is connected to the network? 

Q Well, let me be a little more SpCCifiC. The 

network, is it for the whole building or is it just for the 

area that these employees work? 

A We have a centralized network. We have network 

servers that maintain the post office, common shares that 

5 each different office uses to store documents, and also our 

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I network equipment allows them access to the Internet. 1 

2 Q Okay. Are you familiar with a woman named Monica 2 

3 Lewinsky? 3 

4 A Yes. 4 

5 Q How do you know her? 5 

6 A She worked in the front office, one of the people 6 

7 that we supported. 7 

8 Q Did you have contact with her? 8 

9 A Yes. 9 

0 Q What kind of contact would you have with her? 0 

1 A The contact that I would have with other people 1 

2 regarding suppofi 2 

3 Q So professional advice regarding her computer and 3 

4 software needs? 4 

5 A &u-reCt. 5 

6 Q hythhg e1.W Other than that? 6 

7 A No. 7 

a Q What kind of computer set up did Monica Lewinsky 8 

9 have at the Pentagon? 9 

.O A The same as everybody else, an IBM Pentium PC. 0 

,1 Q Did Ms. &n&y’s computer receive and send 1 

2 e-mail? Did it have that capability? 2 

3 A Yes. It was on the network. 3 

4 Q And it was connected to the network, then? 4 

5 A Right. 5 

Page 15 

I Q Did she have the capability of getting in and out 

2 of the Internet, of accessing the Internet from her computer? 

3 A Yes. 

4 Q All right. Did you ev6r speak to Ms. Lewinsky 

5 about e-mail on her computer? 

6 A I spoke to her on different occasions about mail. 

7 Q Did you ever talk to her on an occasion where she 

8 wanted to discuss with you how to erase electronic mail from 

9. her computer? 

A Yes. 

Q How did that request start? Did she come to you in 

your office? Did she call you on the phone? Did she send 

you an e-mail? Did she send you a note? Do you remember? 

A She called and I went over to the front office or 

on diffu&t occasions wbae I would ans= the phone I would 

answer any question over the phone. 

Q Did she call you directly or did she call some sort 

of general number and the task was routed to you? 

A Everybody called a general number and typically the 

way our office was set up, whenever a request came from the 

front office, specifxally for Mr. Bacon or for Monica 

Lewinsky, I would be tasked to take care of it. 

Q Okay. You spoke with some. agents of the FBI about 

his on a previous occasion, correct? 

A Yes. 

Page 11 

Q And it’s my understanding that, am I’m going to 

just show you a calendar here, if you don’t mind, it’s my 

understanding that you told them that you had this 

conversation that we’re talking about now with Ms. Izwir& 

aboutaweekbeforesbeleftanditwasaf?erawe&nd,is 

that correct? 

A ItwasthtI~dayshewasthtrtatthePcntagon. 

I can’t recall which date. 

Q IfIrepresentedtoyouthatherlastdayonthe 

payroll was cm the 26th and it was aft~~ the wtekend, would 

you agree that it was most probably the 22nd that you spoke 

to her? 

A It was between the 22nd and the 24* I believe. 

Because I don’t recall it being on a Monday. 

Q Okay. So it would have been either the 23rd or the 

24th, but it could have been the 22nd. 

A Yes. It’s one of those days. It was before 

Christmas. 

Q Okay. And it was after the weekend. 

A Yes. 

A JUROR: Excuse me. What month? 

MR. BINHAK: We’re tallring. about December 19! 

I’m sorry. 

BY MR. BINHAK: 

Q All right. How long -- did you have a meeting with 

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Page 17 Page 19 

1 her as a result of the phone call? I day or receive mail within the same day before you C/O% your 

2 A Are you talking about that specific phone call? 2 machine off, it is not saved into your mailbox. 

3 Q Yes. 3 Q So if you get a item of e-mail at, say, lo:00 in 

4 A I met her at the doorway and I believe it was like 4 the morning on a Wednesday and you read it and e- it by 

s a brief conversation. She asked pertaining to the mail. 5 2:OO in the afternoon on that same Wednesday, then it will 

6 Q And let me ask you a question. Do you remember her 6 not bc backed up overnight. 

7 demanoratthetimeyouspoketoheronthisday,December 7 A Or if she did not turn hei machine off. Our ha&up 

8 22nd, 23rd or 24th? 8 procedure was a batch tile that more or less ran an X copy 

9 A The best I could describe it when I spoke with the 9 and it was performed in tbc mornings when people logged in or 

o FBI agents was rushed. She just seemed rushed. 10 when they logged into their PCs after a reboot. So if shy 

1 Q Did she seem ne~ous at all? 11 received mail the same day and deleted it or sent mail the 

2 A The best I could describe it was rushed. I 12 same day and deleted it, then when she exited out of mail it 

3 couldn’t really tell whether it was nervous or not. It could 13 would not be a part of her mail file. 

4 havebeen. 14 Q And did she understand that when you told her that? 

5 Q Okay. You said that you had spoken to her before 15 A- She seemed like she did. 

6 on other occasions. Is that correct? 16 Q Okay. Then did you further explain under what 

7 A Yes. 17 circumstances mail would be backed up? 

8 Q This demeanor that you’re &scribing rushed, was it 18 A I explained to her mail is backed up, Mail is 

9 thesamedemeanorthatshehadhadonotheroccasionsthat 19 backed up. Our backup function is mail is backed up. We dc 

o you had spoken to her? 20 a full backup of all information stored on the network drives 

1 A From time to time, specifically, if Mr. Bacon’s PC 21 on Mondays and Tuesdays through Fridays are differential. 

2 was not functioning, she would seem kind of hurried, but that 22 Q Did you explain to her how long that backup would 

3 particular day, she seemed a bit more rushed than others. 23 last? 

4 Q Okay. How long was the conversation that you had? 24 A I explained to her that we had a four-week 

5 A I can’t recall. I believe it may have been no more 25 rotation. 

Page 18 Page 2C 

1 than a minute. It’s hard for me to tell from something that 1 Q What does that mean? 

2 happened in December. 2 A That xneansthatonthefourthweekweusethetape 

3 Q WeII, let’s put it this way. Was it deftitely 3 set I inthetapetiveS. 

4 less than five minutes? 4 Q SoletmejustmakesureIunderstand Soyouhave 

5 A I b&eve so. Yes 5 approximately 30 or so tapes - or actually, 20 or so if it’s 

6 Q And it was more than just a few brief seconds. 6 four - do you backup on the weekends? 

7 A You’re Iight. Right 7 A No. JustMonday through Friday. 

8 Q Why don’t you tell the grand jury what you 8 Q So there’s approximately 20 tapes, then, and you 

9 discussed during this meeting. 9 usenumhulonone&y,thennumher2andtbenyougo 

0 A She discussed - thz first question was about mail 10 rhrougb and then wbm you gu to tape 20, you go back to oat? 

1 because she had mentioned that Linda Tripp had told her 11 A The week took up six to seven tapes, so six to 

2 something to the effect of when she left the White House her 12 seven times four, 28 tapes. 

3 mail had gotten subpoenaed or something to that effect. 13 Q And then you’d go until those tapes wcrc finished 

4 Q- So Linda Tripp had told - according to Lewinsky at 14 and then go back. 

s this meting, Linda Tripp had told Izwinsky that when Linda 15 A ThefifthweeIc,weusedtheset 1. 

6 Tripp left the White House, Linda Tripp’s e-mail had been 16 Q All right. So something that was backed up and on 

7 subpoenaed. 17 the tape would be held on that tape until that tape was 

8 A Something to that effect. Correct. 18 reused. 

9 Q And what else did she say? 19 A Right. 

0 A She had asked me about our backups and about the 20 Q And that took approximately four w@s? 

1 way our e-mail was stored. 21 A Ri&t. 

2 Q And what was your response? 22 Q Didsheseemtounderstan~whenyoutoldherthat? 

3 A I explained to her the way that our e-mail 23 A I gueSS SO. Yes. 

4 functions is that our c-mail is on the hard drives and if you 24 Q Did she ask you for any particular help with 

5 receive mail the same day or you send mail within the same 25 problems? Did she indicate what she was interested in doing 

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Q And you mentioned how to delete within 24 hours I 

think to de!ete right away before it ever got to be backed 

UP* 

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1 other than asking you about general information? I 

2 A She didn’t go any further about why she was asking. 2 

3 Q Did she describe to you that she wanted to erase 3 

4 e-mail files from her own computer? 4 

5 A Not specifically. 5 

6 Q Did you get that impression from talking to her? 6 

7 A I got tlkz impression that -- usually when people 7 

8 leave public Affairs, generally people will ask me about how 8 

9 to go about removing their mailbox. They don’t ask me abou 9 

o the backup procedures, but they do ask me about removing th 0 

I mailbox. So I didn’t really put that much relevance in it. 1 

2 Q Did you get a sense whether Ms. Lewinslcy was more 2 

3 concerned with files that she sent or more umcemed with 3 

4 files that she received? 4 

5 A She didn’t really specify. She had asked me abou 5 

6 other people sitting at her PC and whether they could send 6 

7 mail. That’s the full extent to which she described it. 7 

8 Q Okay. After this short conversation that you’ve 8 

9 just described did you hear from Ms. Lewinsky again about 9 

.o this issue? 0 

!I A No. 1 

:2 Q Do you know where she went after you discussed this 2 

13 with her? 3 

:4 A I believe she went back to her desk. I went back 4 

:5 to my office. 5 

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Q Did MS Ixwinsky ask you any other questions about 

files on hard drives or on her hard drive or how to erase 

them? 

A I don’t recall. 

MR. WJSENBERG: Could I ask a question, Steve? 

h4R. BINFLAK: Of course, you may. 

BY hiR. WISENBERG: 

Q Mr. Sparks, if I heard you right, you mentioned 

that Monica - said originally came to you and said sornethin~ 

to the effect that Ms. Tripp had told her that e-mail gets 

stored on hard drives. Is that correct? 

A Something to that effect. Right. She didn’t 

specify that it was stored on the hard drive. She 

specifically more or less was saying that Linda Trip had told 

her that at the White House they were able to subpoena her 

mailbox. She didn’t tell me the technique or where it was 

stored. 

Q Okay. I thought I had heard you mention hard 

drive. Did you tell her that -- maybe it was that you told 

her that e-mail was on the hard drive. 

A That e-mail was stored on the hard drive? Yes, 

Sir. 

Q Okay. Then my question is we’ve talked about -- 

that you mentioned to her the backup, the four-week backup. 

A Right. 

A Within the same window session. 

Q Okay. What, if anything, did she ask you or d3 

you tell her about the problem of getting it off the hzd 

drive itself? 

A I don’t recall specifically telling her how to get 

it off the hard drive. I just instructed her that the wan. 

that our mail functions is that because it is a dynamic file, 

while you’re in mail, when you receive mail, when you sad 

mail, the fii changes. 

And I instructed her that if she received mail at 

2:00, as soon as she read it she deleted it, when she exir 

out, it eiirpties out her waste basket which is her delete mail 

folder. And the next morning when she logs in, that will not 

be a part of her mail file. 

Q But if she’s an employee who’s leaving and stre’s 

concerned about, among other things, past e-mail, erasing 

past e-mail wouldn’t you need - wouldn’t she need to know 

information about how to get rid of that e-mail that’s stored 

there on the hard drive? 

A I aSSumeSO. Yes. 

Q Is it possible that you all discussed this and you 

just don’t recall or what? 

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A I explained to her that we back up, we do full 

backups on Monday and on a Monday, whatever was in ha mail 

box or Tuesday through Friday, if she was at work and her 

mailbox was changed, it would be on a tape. 

Q Okay. But what about the issue of -- let me 

explain to you that you’re probably talking to the most 

computer illitera$ person in the room, so have a little 

patience with me here. 

A Yes, sir. 

Q But that still doesn’t speak, what you just said, 

to the issue of the stuff that’s still stored on the hard 

drive, right? I nrean, she hasn’t gotten rid of it within the 

window, it may even be beyond the four week period, but it’s 

neverbeenaasAoffoftbehanidrive. Ifsbe’sconcemed 

about that, about erasing her e-mails, wouldn’t that still be 

a problem? 

A If you’re asking me technically, yes. It would be 

backedupmcmeofthetapes. Ifyou’reaskingrneifshe 

asked me specifically about that, I don’t recall us ever 

getting that much in depth into that issue. I guess I’m 

misunderstanding what you’re asking me. 

Q probably it’s just my ignotaru~. What do you mean 

by tape set? 

A We have, as I was explaining, we have a four-week 

rotation, so four weeks, for each week, we use a tape set of 

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In re: Grand Jury Proceedings Multi-Page m Floyd Sparks, Jr., 5-12-98 

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1 six to seven tapes. Now, last M&y, whatever was your 1 The original file you will not be able to pull up 

2 mailbox conteat, w have up on tbc backup. This Monday is a 2 and retrieve because it’s been written over and that’s 

3 different set. And if I want to restore what you had on your 3 what -- I guess that’s why I’m trying to explain it. a 

4 tape set last Monday, I could go to the last week’s set. 4 mailbox file itself, every time you receive mail, it cm&s 

5 Q But that’s a network wide system, correct? That 5 a new mailbox file. So it’s one file. All you mai] 

6 you’re describing_ 6 messages go into that one file. 

7 A The backup function? 7 BY MR. WISENBERG: ’ 

8 Q Right. The tape backup function. 8 Q Okay. And are you saying that when you do that 

9 A Right. 9 you’re going over, youre ’ writing over on the cornput& 

0 Q And that doesn’t -- correct me if I’m wrong, that’s 10 A You’re writing over that file. Correct. 

1 not literally stored on the hard drive of her desktop 11 Q But you don’t remember discussing this Specific 

2 computer, is it? 12 issue with the issue of stuff stored on the bard drive ant 

3 A The mail fde is stored on the hard drive of her 13 how to get rid of it with Ms. L&n&y? 

4 camputcr. when sk backs up in tk mornin&WhcntllCpersoll 14 A I explained the way -- and, again, the way I 

5 logs into their machine in the morning, a batch file copies 15 remember the conversation, I was more so talking specifically 

6 all of the specific files, more specifically documents, 16 about the mail file that gets backed up. That’s what I 

7 spreadsheets, mailboxes, up to a backup network drive. 17 thought she was asking me about. 

8 Q Okay. What happens to the stuff that’s on the hard 18 Q Do you recall discussing software with her? That 

9 drive? 19 is to say did she ask or did you recommend any software she 

0 A It Stays there. 20 could purchase to help her erase files? 

1 Q Okay. And that’s my question. If you’ve got a 21 A Just do a full erase, to do a non-retrievable erase 

2 person like Ms. L.cwinsky who has apparently come to you, and 22 on the hard drive? 

3 I’ll try to shut up in a minute, and has a concern about 23 Q Right. 

4 erasing among other things e-ma& she’s still got --just as 24 A No, sir. 

5 a theoretical issue, she’s still got to worry about the stuff 25 MR. WISENBERG: I’m sorry. I’m done. 

Page 26 Page 28 

1 that’s still stored on the hard drive itself, doesn’t she? 1 MR. BIMFAK: Go ahead. 

2 A Well, not necessarily because as soon as you delete 2 BY MR. TRAVERS: 

3 mail messages and you exit out of mail, if you have 500 mail 3 Q Just to clarify, if you have, using your example, 

4 messagesonthatmailfieandyou&lete400ofthem,when 4 500mcssa@zsinyolUma%oxandyoud&c400oftln&dlal 

5 thenzwas500ll&1 mssages, it could have been a mailbox 5 wyouharddrivt,onyourcomputa.youbave,1OObutoattw 

6 fileof4megabytes. WbcayOUddczc4OOmtssagesofthaf 6 backups that you described frcnn the -ark drives, you’re 

7 it becomes maybe,a 2 megabyte or a 1 megabyte file, so 7 still going to h&e those 500 messages backd up. 

8 actually that’s what I was saying, it’s a dynamic mail file 8 A From the previous backup. Correct’ 

9 because once you delete all those out, then the only thing 9 Q From the previous backup. And that wilI last for 

o that’s left is whatever is in your mailbox. 10 approximately four weeks? 

1 MR. WISENBERG: I don’t understand but maybe ii A Yes. 

2 someone else can pick up and help me on this. 12 Q So if somebody has 500 messages on their hand drive 

3 A JUROR: Sol, the question that you’re asking 13 and they want to delete 400 and they want to delete those 

4 relates to the hard drive itself wherein someone would have 14 permanently, its ’ important to know how long the backup is 

s deleted a stored message on the hard drive. 15 going to be around. 

6 What Sol is referring to is that everi though it’s 16 A 1 guess so. Yes. 

7 been deleted., it can be accessed if it’s not been written 17 Q And you would also want to know exactly how 

8 over. He’s referring to that. It can be retrieved, I should 18 something is backed up. 

9 say, rather than accessed, if it hasn’t been written over. 19 A Yes. 

0 THE WITNESS: Well, I mean, I guess the best 20 Q How those are stored. 

I analogy I can think of is if you have a Word doe-t. you’ve 21 A Yes. 

2 created a letter you wrote to somebody. When you save it. 22 A JUROR: So on my e-m@1 screen that says I have 

3 its ’ a certain file size. Tomorrow, you come in, you change 23 500 messages and I delete 400, so on the screen there’s only 

4 the contents of it and you save it and you save it three or 24 100, but on my hard drive, I still have those 500 becam 

s four different, three or four more iterations of it. 25 they haven’t been written over yet? E-mail is deleted off my 

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screen, but still on the hard drive because it hasn’t written 

over? 

THE WlTNESS: With the way that our mail system. 

the way that the client mail software worked, CC soon as you 

deleted something, it went into a deleted or a wastebasket 

folder. On most of the PCS, the setting is as soon as you 

exit out of mail, it purges that wastebasket so then those 

files are no longer a part of -- those mail messages are no 

longer a part of that mail file. 

A JUROR: And you say that software like Norton 

Utilities can pull those up sometimes? 

THE Wll?4EsS: &xiuse it’s the same file, I’ve 

never tried to do a restore, especially on a file that 

changes as often as the mailbox file, so as far as I know you 

cannot. 

A JUROR: Did Monica Lewinsky specifically ask you 

how to delete mail messages? 

THE WlTNESS: Yes. 

A JUROR: And what was your response to this fact 

scenario you just gave us? 

THE WlTNESS: Just to hit the delete key. You find 

the message, you delete the mail message. And actually that 

kind of a question was, you know, most users will ask that 

and once they figure it out, it’s actually something you 

don’t even have to ask because it’s rather intuitive with the 

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A JUROR: Okay. Excuse me, then. Let me clarify. 

during this discussion between December 22nd and 24th, did 

she ask you about deleting messages, deleting her e-mail 

messages? 

THEwlTNBss: Yes. 

BY MR. TR4VERSz 

Q And just to clarify, when you hit the delete key 

and delete that message, most likely it’s going to be around 

for four more weeks on your backup system? 

A Well, if on Monday you backup, Monday that you turn 

on your machine, it backs up that mail file up to the 

network, Monday night it m backed up. Tuesday you come in 

and you delete all those messages on your hard drive, those 

mail messages will not be, but on the tape from the previous 

night they will. 

Q Right. So there will still be a backup of those. 

A Right. On the network as well as on the tape. 

Q And you explained to her the system by which those 

backups are made. 

A Yes. 

Q And how long they’re kept. 

A Right. 

A JUROR: What I understood you to say earlier is 

that the e-mail that you receive is saved on your hard drive 

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in a specific location such that even if you delete it. CE 

next morning when you have additional mail, one would wre 

it in that same spot_ so it’s written over the old delete2 

messages. 1s that correct? 

THE WlTNESS: No. The mail file itself, it’s ju.? 

one large file. If you delete a mail message, it’s just &I 

deleting a page off of a document. The page goes away. I 

mean, that’s the best way I can describe it. I can’t figure 

out a better way to describe it, but if you delete a page off 

of a document, it’s the same concept and you add in anotkr 

page and that’s the way -- when you receive mail in, it’s 

like adding another page. 

If you go to page 2, you decide you don’t want it 

any longer, you delete the entire contents of page 2 and ycr~ 

save that document, then page 2 is no longer there. 

BY MR. WISENBERG: 

Q It’s no longer where? 

A It’s no longer on the hard drive in that one 

specific file. 

A JUROR: Does it get written Over? 

THE WITNESS: Yes. 

A JUROR: By the next message? 

THE ~ITNES: No. The messages - it’s like having 

a pail and as you get messages you’re throwing these items 

into that same pail. If you decide that you don’t want some 

Page 31 

1 of those items out of that pail, you just take them out of 

2 the pail and the pail itself more or less will grow as you 

3 acldmoreitemstothepailandtheumtentswilldaxeaseas 

4 youtakemoreitemsout I’mtryingtothinkofthebcst 

5 analogytodescribtifbutthat’sascIoseasIcanget 

6 BY MR. WISENBERG: 

7 Q Andthepaifiswhat? ‘Ykpailistkharddrive 

8 or the pail is your screen that’s showing you all the 

9 messages? 

0 A The pail is the mailbox file. It’s that one file. 

1 Our mailbox - the mailbox is just one fde. 

2 A JUROR: On the hard drive? 

3 THE WITNESS: Yes. 

4 BY MR. TRAVERS: 

5 Q So if the pail is full with 500 messages and you 

6 delete 400, the next day your pail is mostly empty. 

7 A ti-hmm. 

8 Q Then it’s going to be very difficult to get those 

9 400 deleted messages from the hard drive, because you’ve 

3 overwritten the mailbox file. 

1 A Right: But it’s not impossible to pull it from tht 

2 network backup. _- 

3 Q Because there's a copy of the full pail on the 

I network. 

5 A On the tape. Yes. 

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I read that document to you? I evidentiary integrity of computers? 

2 A kim-hmm. 2 A Can you repeat that? 

3 Q Okay. These are actions that were taken in order 3 Q Is there a protocol or a methodology that either 

4 to -- in response to a subpoena from our office for Ms. Tripp 4 Booz-Allen has in place or the Pentagon has in place fol 

5 and Ms. Lewinsky’s computer. is that correct? 5 responding to subpoenas for computers in order to maintain 

6 Mm-hmm. 6 the evidentiary intq-ity of the computer? That is, to make 

7 MR. WISENESERG: You have to say yes or no. 7 a full copy of everything, erased and non-erased, on a hard 

8 THE WITNESS: Oh, I’m sorry. Yes. 8 drive? Are you aware Of -- 

9 MR. WISENBERG: Thank you. 9 A Not that I’m aware of. No. 

0 BY h4R. BMHAK: I 0 Q So you’re not aware of one at Booz-Allen? 

I Can you describe, and you can use that document to 1 1 A No. 

2 refresh your recollection, if you’d like, what actions wtze 1 2 Q And you’re not aware of one at the Pentagon. 

3 taken with regard to the subpoena. 1 3 A Cornxt. 

4 A I remember taking Linda Tripp’s PC and using 1 4 Q When you were told to backup Linda Tripp’s 

5 Laplink and making an exact duplicate of her PC and taking 1 5 cornput&, did you know that that was in response to the 

6 that one back downstairs to her office. I 6 subpoena? 

7 Q And let me ask you a qllestion about Linda Tripp’s 1 7 A In the back of my mind, I figured it had to do witl 

8 computer and Laplink. Wkn you use Laplink, my understanding 1 8 something with that, but we were not ever told directly that 

9 is that that’s -- you take a cable and you connect two PCS 1 9 it was a subpoenaed item. 

:0 and by virtue of the cable and the software you make a 2 0 Q Did anybody tell you to use the Laplink process t( 

!I duplicate of the files that are on - if you have computer A 2 1 duplicate the fties on her computer? 

12 and you bavc computer B and computa A is the computa you 2 2 A In the capacity of my job, they asked me if there 

.3 want to make a backup of, you co-t computa B tn compu%z 2 3 wasawaytomakeanexactcopyofherharddrive,takethe 

:4 A, you use the software and then computer B contains all the 2 4 copy or the duplicate machine down there to her desk site and 

.5 tiles on computex A. IS that COXTWt? 2 5 the only way that I knew of to do that was with L.apIinlPage 38 

A Yes. 

Q Okay. That’s what Laplink does. 

A Correct. 

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Q So it was your decision, then, to use the L&ink. 

A Yes. 

Q But you’re saying right now that that would not 

maintain the integrity of the unsaved or c&ted or not live 

files on the computer. 

Q That Laplink process will only copy and duplicate 

live files, correct? 

A conect. 

Q It will not duplicate the slack space on the 

computer or any files that arc not active. 

A That were deleted, no. Not that I’m aware of. / 

Q Okay. Now, are you familiar with the subpoena that II 

our oftice sent over to the Department of Defense for Linda 1 

Tripp’s and Monica Lewinsky’s computer? 1: 

A As far as I remember, wt? were just told to take 1 

careoftheseitemsandthattheFBIorsomebodywasgoingto 11 

come and take possession of them. 1 

Q Okay. Let me ask you this question. If you wanted 11 

to preserve the integrity of a computer in the sense you 1’ 

wanted a complete duplicate of the entire hard drive, would 1: 

you use Laplink to do that? 1’ 

A Down to even the deleted files? 21 

Q Ye.% 2 

A No. 2: 

Q All right. Is there a protocol that you’re aware 2: 

of that Booze-Allen or at the Pentagon in general for 2s 

responding to subpoenas and maintaining the documents, the 2: 

A Asfaras-likeIsaid,thewaythatthe 

informationwasd&minatedtomewast&yw20tedt4take 

possessionofLindaTripp’sPcbutatthcsameti.mehavea 

duplicate copy. 

Basedqonthatinformation,gi~thefactthatwe 

were going to take a duplicate down to her desk site, tha 

WasnotthePCthatwasgoingtobetakenintocustodyo 

whatever, so that was the recOmmen&tioClthatIh&ldbSCd 

upon the utilities that we had. 

Q All right, I’m just trying to find out exactly 

what happezd, so don’t take it as though I’m accu&g youol 

anybodyofanything. We’rejusttryingtogettoexaetlywho 

madcthcdccisioasandwhatQccisionswatmadZsoIctmgo 

over this thing again slowly. 

Based on what you told, that there was a duplicate 

machine coming down to Linda Tripp’s desktop and that her ’ 

machine was going to be taken away auddut somcwbcmelsetmd 

youwrretoldtomakesurethatthcnewmachinethatwas 

coming down would be an exact duplicate of wixtt Linda Tripp 

had on her machine, is that correct? 
3691 

In re: Grand Jury Proceedings Multi-Page= Floyd Sparks, Jr., 5-12-98 

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Page 41 

Q And so in order to perform that task that you had 

been assigned, you used this Laplink system to make tl~ 

duplicate machine, an exact copy of the machine that was 

formerly on Linda Tripp’s desk. Is that correct? 

A correct. 

Q But you’ve just told the grand jury now that by 

using the Laplink system that you are only duplicating the 

live files on Linda Tripp’s machine. Is that correct? 

A COI-IWt 

Q Okay. so then in fact it was not an CXaCt 

duplicate that you made, it was just a duplicate of the live 

filesandthatanythingthatwaserasedorintheslackspace 

of Linda Tripp’s computer would not have been on the 

duplicated machine. 

ACOlTeCtQ Now, is it accurate to say that jus? by doing the 

Laplink process that some of the slack space on the Linda 

Tripp original machine would be altered because there would 

be some overwriting as part of the process of using Laplink 

and duplicating? 

A No. 

Q That is not true? 

A No. As far as I know, with Laplink, Laplink does 

not affect the machine that you’re copying from. It takes a 

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Page 42 

copy of those files. It’s just like copying a file from your 

hard drive t0 a floppy, You’re not changing the composithm 

of that file that’s on your hard drive when you copy it tc 

the floppy. And, in essence, that’s all that Laplinlc does. 

Q Okay. Now, when you booted up Linda Tripp’s 

computer, the original Linda Tripp computer, in order tc 

start the Laplink process, would that have changed or 

overwritten the contents of the slack space in Linda Tripp’s 

hard drive? 

A Only if when you run the backup it changes the 

archive bit on those files, which does not change the file 

composition, but it changes the archive bit because that? 

the only way we can tell whetber a tile’s been changed. And 

I don’t recall whe&r or not I canceled the backup when I 

booted her machine up. 

Q Okay. So it’s possible, then, that some of the 

contents of the hard drive would have been overwritten or 

changed as a result of booting up the machine. 

A The only thing that would change would be the filr 

attributes. 

BY MR. TRAVERS: 

Q What about Windows temporary files? 

A When you boot up Windows, it will purge the 

temporary files. 

Q And when you say purge -- 

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A It erases them. 

Q It erases them? 

Page 4 

A Actually, as soon as you exit out of Windows, if 

you do not have an abrupt exit out of Windows, those 

temporary files are for the most part deleted. 

Q And when you booted up Linda Tripp’s computer, did 

you boot up Windows? 

A Yes. 

Q So when you booted up Linda Tripp’s computer, 

did purge the Windows temporary files? 

A It possibly could have. Yes. If you’re asking me 

definitely, no, I don’t know. 

BY MR. BINHAK: 

Q Is there a way to copy a hard drive exactly such 

that nothing will change, not even a purging of any tempofdes or any other files on the hard drive, saved or unsaved? 

A I’m sure there is, but I don’t know of it. 

Q Did anybody tell you to not use such a process on 

Linda Tripp’s computer? 

A The Laplink? 

Q Did anybody instruct you to not use a system that 

would completely copy exactly the contents of the hard drive 

as it was when it was sitting on th desk before you got 

there? 

A Im ’ sorry. I’m trying to understand. You’re 

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Page 44 

saying did anybody instruct me not to use a utility that 

would make an exact copy? 

Q Yes. 

A No. 

BY MR WBENTSERG: 

Q Isn’t that called imaging? Isn’t t+znz something 

called imaging *here you can mah - you’re essentially 

taking a picture of the hard drive and you don’t lose 

anything, like losing teznp files you talked about? 

A Ifthetempfilewasontheharddrive,thenit 

would havt been copied over because it’s an actual file. 

LikeIsi3id,nooneinstructedmenottousesomethingthat 

would make an exact copy. No OIE ins-d me. 

And, like I said, based upon my best professional 

knowledge,IfiguredLaplinkwastheonlywaythatllcnewoi 

to mabz an exact copy of a hard drive regarding the. filez 

that are visible to the user. 

Q HOW about this imaging that I mentioned? Are youfamiliar with that? 

A I’ve heard that there is imaging software, but I 

was more familiar with Laplink, so I couldn’t speak to you of 

this imaging software. 

Q Do you know what imagingis? I mean, for those of 

us who aren’t experts. If you could give us a nutshell 

definition of imaging. 
3692 

In I-C: Grand Jurv Procccdims Multi-PagcTM Floyd Sparks, Jr., 5-12-98 

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Page 45 

A I guess the best way to describe it would be if you 

were looking -- it’s like taking the hard drive and taking 

its reflection out of the mirror and placing it at a 

different destination. 

BY MR. BINHAK: 

Q So you did not do that process, the imaging 

process. 

A No, I did not. 

Q And no one told you not to do that? 

A No, they did not. 

Q That was a decision you made on your own, based on 

the tasks that you were given. 

A Yes. 

Q Do you remember who gave you the task to deal with 

Linda Tripp’s computer, duplicate it? 

A To be honest, I don’t recall. It would have been 

either Rick Silva or Bonnie Nicholson. 

Q Did anybody suggest to you or intimate to you or in 

any way instruct you that it would be okay not to have 2 

complctc image of Linda Tripp or Monica Lcwinsky’s bard drive 

when you were doing the duplication? 

A No. 

Q Did you have anything to do with Monica L&n&y’s 

computer and the duplication of that? 

A As far as I remember, they just took possession of 

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Page 46 

bersbceauseattbattimeanewpersoncameinandtbeygave 

heranewPC. Iwasnotintheofficeatthetime. There 

werethreeorfour&ysIwasnotinwhilethcy~doing 

some of these things. 

Q Okay. So you dealt with Linda Tripp’s but not with 

Monica Lewinsky’s. 

A Gorreet 

Q Were you at any of these me&ingS that SWTOUdeK 

the decision - let me ask it a different way. Did you 

attend any of the meetings wbem there was a decision made 

about what to do with Monica Lewinsky’s computer or Linda 

Tripp’s computer in response to a subpoena from the Office o. 

Independent Counsel? 

A No, I was not. 

Q So you were simply following the instructions thal 

were given to you from people who attended the meeting. 

A hTeCt. 

MR. BINHAK: All right, Mr. Sparks. Let me ask you 

to just step outside of the room for a moment. There’s a 

possibility that the grand jurors will have some additional 

questions for you. If they do, I’ll ask you to come back. 

If not, you will be free to leave. 

And, Madam Foreperson, just for the record, there 

were: no unautborizcd people in rhe room and we had a quorum 

the whole time. 

Page 47 1 

1 THE FOREPERSON: Absolutely had a quorum. 

2 h4R. BINHAK: Thank you very much. 

3 (The witness was excused.) 

4 (Whereupon, at I:00 pm., the taking of testimony 

5 in the presence of a full quorum of the Grand Jury was 

6 concluded.) 

7 ***** 
3693 _ 

To: WHOM IT MAY CONCERN 

I 

ROUl: Bonnie Nicholson 

Date: . January 27, 1998 

Subject: Computer Requirements 

On Friday, Jan 23, 1998, returned from meeting with CAPT 

Doubleday, Pat Bursell, Celia Hake, Jamie Graybeal, Rick Silva, 

and Bonnie Nicholson after a diScuSSiOn about the turnover of 

computer equipment to General Counsel. I was told to'take 

Monica's and Linda's PC and give them another PC. The following 

actions- took place with Rick Silva, Floyd Sparks, Chris Harrell, 

Jodi Johnson, Traci Antonson, Nancy Gorski, LT Seaman, Quigley, 

and Pat Bursell. The dates for the actions are from January 23, 

1998 to January 27, 1998 at 12: 0 P.M. for IRM. 

l (3rl.5.P-M .-,-Jan=-- 23) perfo ru& 

.-.. . . _ 

a backup-of _Monica~'s~C'SO -2 

info could be &pied to another .PC for-F&. Shender (b&ET QUA-j\ 

. checked Ms. Shender's backup for accuracy 

i took PC from MS; Shender's desk‘ and put in IRM'I&b 

. took another PC to Ms. Shender's desk and setup the calendars 

and update macros 

l discussed in meeting that several copies of the info was 

required. At that time, Rick Silva went to BTG to purchase 

the ZIP disks for the copies 

l Priday,(4:15 cm), Jan. 2~) Rick silva aisc.-.g&~&~ fi+ ’ .@-.-* 

and putin ’ IRH lab"fbr a backup. and a laplink process .of info 

to another CPU. Worked was completed and on Saturday, 

took the CPU to DPCR and installed at Tripp's desk( 

Floyd+Ptb 

l Floyd Sparks did all of the backup copies which includee! 

Monica's and Linda's complete backup for three weeks and the 

mailboxes on Friday, Jan 23 and Saturday, Jan 24 

l Monday, Jeuary 26, a meeting was held in the FO. Attendees 

were Mr. Bernath, Mr. Wilson, Pat Bursell, Bonnie Nicholson, 

Celia Roke, CAPT Doubleday. At that time, the discussions 

were about Tripp working at home, 

mail, 

who will print Tripp's e- 

\ j$JJ 

and status of computer printouts, 

Monday, January 26, Traci Antonson viewed all contractor's' 

>-=;-. yL 

c 

mailboxes for verification for mail to and from Tripp and 

:z 

Lewinsky. All documents were given to Pat Bursell. 

Silva gave Pat Bursell his info on Friday, Jan. 23. 

Rick 

/ i'Monday,'.Jami~"'Za,' Chris. connected Tripp n 6’ and %ewhkym r.bid ’

_PC to the network:---.. At that'tiriie'-;"hd'st~ed-"pz;kig'ail 'info 
3694 

pg+ -~g~;~~5y=$y$-== ;=z 

Offi&eT startiag printing Tripp's e-mail. 

JI 

WOUXI 

PC vas relocated t0 bM, 2E811, for another person 

4 P.M. the 

the task of printing Tripp's mailbox. 

to pickup 

A6 of Tuesday, 11:30 

A.M., XRM doesn't know the status of the print task. 

l On Monday, Jan. 26., Pat Bursell was having a telephone 

coversation with Brad, GC. Bonnie walked into Pat's office 

and was asked to join the conversation. Brad ask what the 

type of media would they be receiving. I explained to him 

that we used zip disk and he would need a zip drive and 

PICUNZIP software. He said &e wasn't computer savvy and he 

would check with his computer support-# I haven't heard or 

receivdany messages from him on this subject. 

l On Tuesday, Jan- 27, a meeting was held in the PO with Mr. 

Bernath, Pat Bursell, Nancy Gorski, Jamie Graybeal, and Bonnie 

Nicholson. The only part of discussion IRM participated was 

the discussion of the computers. Previous info within that 

meeting that was discussed, IRM has no knowledge. 

l On Tuesday, Jan. 23, three sets of zip disk (9 per set) were 

given to Pat Bursell. 

and Lewinsky backups 

The contents of the tapes are Tripp 

for l/23/98; Tripp and Lewinsky backup6 

for 12/29/97 and l/5/98; Tripp'e mailbox; Lewinsky's mailbox. 

bother set of tapes will be put in DM's safe in 2E811. 

_ _. . _-. - .- 

l . On'Tuesday, 

-.. _.. 

'Jan; 27_;%ewinskyW~CPU wzW'~~m-fat-3u,rs~;__ 

with a hand receipt, 

signatures.- 

Pat Bur6ell will follo&-up with-Gt'for 

7 l On Tuesday, Jan. 27, some tapes of transcripts were found in 

the PO travel computer bag. All tapes were given to Mr. 

Y Bernath. 

TOTFY. P.03 
OK-302 (Rev. 8-19-94) 

- 1 - 

OFFICE OF THE INDEPEhBENT COUNSEL 

3695 

Date of nanscnption 4/20/98 

FLOYD SPARKS, JR., Computer Consultant, sub-contractor 

from BOOZE, ALLEN, & HAMILTON, INC., and assigned to the Office 

of Information Resource Management (IRM), U.S. Department of 

Defense, was interviewed in the offices of the Pentagon General 

Counsel, on March 9, 1998. Also present was Ms. IVEY MARTINS, 

Corporate Counsel, from BOOZ, ALLEN, h HAMILTON, INC., 

8283 Greensboro Drive, McLean, Virginia, and Deputy General 

Counsel for the Pentagon, BRADLEY WEIGMANN. Representing the 

Office of the 

Investigation 

After a brief explanation of the purpose of the 

interview, SPARKS advised that MONICA S. LEWINSKY had requested 

his assistance on how to erase certain files and e-mail messages 

from her desk computer located just outside the Office of the 

Secretary of Defense for Public Affairs, KENNETH BACON. This 

request came approximately one week prior to her resignation, 

because he had already been notified of her pending departure. 

He was not approached personally by LEWINSKY, but was assigned to 

assist her after she contacted the IRM help line. When they met, 

she acted excited and agitated about her concerns in erasing 

information and pressed SPARKS for instructions. 

LEWINSKY told SPARKS that, based on discussions she 

had with LINDA TRIPP, LEWINSKY understood that deleted files and 

e-mail from her computer could still be retrieved later, unless 

erased. LEWINSKY was concerned that other employees who 

occasionally_utilized her computer could retrieve and.read her 

personal communications. She was specifically concerned about 

e-mail she had sent, more than ones she may have received. 

SPARKS instructed LEWINSKY on how to erase her e-mails 

in a brief meeting just outside her office. He explained that 

e-mail messages received or sent, which were deleted the same 

day, did not get automatically backed up in the Pentagon's backup system. All other messages were recorded and saved for four 

weeks on a rotational schedule at an off-site facility. This was 

done to maintain the integrity of__the computer files in case of a 

investigation on 3/09/98 it Washington, D.C. Ftic, 29D-OIC-LR-35063 

_, 

by Date dictated 4/20/g-8 
3696 

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

29D-OIC-LR-35063 

Connnuamn of OK-302 of FLOYD SPARKS, JR. ,On 3/09/98 .Fqc 2 

national emergency. After four weeks, tapes were rotated back 

and used over again to record communications. Once new 

information was recorded over the backed up information, the old 

information was written over. 

SPARKS advised that once he carefully explained the 

procedures to LEWINSKY she returned to her desk. He never 

physically went to her computer, and he was never re-contacted by 

LEWXNSKY for further assistance. 

that he had solved h& problem. 

In his opinion, SPARKS believed 

He also had no information, or 

knowledge, that any other IRM computer specialists were ever 

enlisted by LEWINSKY to provide further assistance. 

According to SPARKS, his boss, BONNIE NICHOLSON, had 

instructed IRM employees that it was a department policy to 

provide instruction, but not actually perform operations for 

employees seeking advise. Additionally, there was a policy that 

IRM employees were forbidden from entering an employee's personal 

computer to delete files. However, IRM did issue bulletins 

encouraging employees to occasionally erase old temporary, cache, 

and e-mail files in order to make space on the hard drive which 

had a finite capacity. 

SPARKS advised that neither he nor his IFU4 associates 

were provided the computer software tools such as 'utilities,' 

which could permanently erase information from a hard drive. He 

also advised that he had no software to perform image processing 

of a hard drive. 

MS: IVEY MARTINS, the B&Z, ALLEN, & HAMILTON, INC. 

attorney, representing SPARKS and their employer requested any 

further contact with her client be channeled through her office. 

Thereafter, SPARKS provided a home address of _ 
3697 

George Stephanopoulos, 2/3/98 

Grand Jury 

Page I to Page 113 

P 

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: 202-514-8802 

-. 
3698 

Page 1 

esA George Stephanopoulos, 2l3/96 

Page 5 

“WAX,., 1..--., 

~.___ 

11; UNITED STATES DISTRICT COURT 

FOR THE DISTRICT OF COLUMBIA [;: _______ _________x 

[31 IN RE: 

[41 GRAND iJURY PROCEEDINGS : 

I51 

I61 

[,!________________X 

19! Grand Jury Room No. 4 

191 Umted Slates Dlstnd Court 

1101 for the District of Columbia 

I::; 

3rd 8 Constitution. N.W. 

Washington, DC. 20001 

I131 Tuesday Februa 3 1998 

The testirnoriy of GEORGE ROBERT STEPHANOPOUL 

i::itaken in the presence of a full vorum of Grand Jury 97-2. 

[16]1m 

(171be P ore: 

aneled on September 19. 1 97, commencing at 1:53 p.fn.. 

1181 BRUCE UDOLF 

1191 SOLOMON WISENBERG 

1201 STEPHEN BINHAK 

[Ill DAVID BARGER 

I221 

[231 

[241 

I251 Washington, D.C. 20004 

.os was 

(1 IMr. Udolf has now left the grand ury room, 

(1 l~ecord reflect there are no 

and let the 

unaut &xl2 ed 

[31~ury. Is that ri ht. Madam Foreman7 

THI? FOREPERSON: 

persons in the grand 

I41 That is correct. 

151 BY MR. WISENBERG: 

isi .a, 

(7 1 responslblltites as 

Im ’ nOW going to read YOU oy;ld$;; and 

a 

:8 lpnvllege lfg 

rand jury qss. uy 

against se -incnm!nat!on. which means you may 

19 1refuse to answer an 

[ :o 1 uestlon wouM ten 

s, 

dy.. 

questlon d a tntthful answer to the 

rlljt at? 

to lncnmlnate you. Do you understand 

I121 A I do. 

1131 Q Anything you do 

114 lgrand jury or rn a subsequent lega “I 

may be. used against you by the 

il5lundentand that? 

proceeding. Do you 

1161 A I do. 

1171 Cl If you have retained counsel, of course, he or she 

[I B Icannot sit w$h you in the grand jury room here, but tne 

[lslgranci JU 

x 

WIII pevit you a reasonable 0 

[zoloutslde t e grand jury room to cwsult w ip 

portunity to step 

121 ldesire. Do vou understand that? 

h counsel if you so 

i22j A- I do. 

1231 Q 

[24]ComXt? 

I understand you have counsel here today; is that 

1251 - A That is. 

Page 2 

Cl1 

(2lWhereupon. 

I31 GEORGE ROBERT STEPHANOPOULOS 

[I Iwas called as a witness and having been first duly sworn b 

rslthe Foreperson of the Grand Jury, was examined and test if& 

f 6 1 as follows: 

[71 EXAMINATION 

[El BY MR. WISENBERG: 

Q Ive ’ been asked to ask you to both state and spell 

r:ilyour name for the record. 

ill1 A My name is George Robert Stephanopoulos. And its ’

[I 2 1 spelled S-t-e-p-h-a-n-o-p-o-u+o--Co-s. 

Q 

[ii; Im ’ an attorney for the Oft%e of lnde 

Mr. Stephanopoulos, my name is Sol Wisenberg, and 

ndent Counsel. With 

[151rne today are my colleagues, David I? arger, Steve Binhak. and 

[I 6 I Bruce Udolf, also of the Office of Independent Counsel, as 

[171well as the coufi_ reporter and the members of the 

(181 Im ’ gomg to start off by explaining a few 

rlg]about,our authority. and what were ’ doing here, as wel 

[zolyour nghts and responsibilities. 

I will occasionally ask ou whether or not ou 

Ii:;understand what Im ’ sayin a 

1231~No.” “Maybe ” as oppos 

J, r&II ask you to say +es,- 

rzcluh’ or”Uh-huh.” 

to shaking your head or saying Uh- ‘

1251 A Right. 

Page 4 

Q 

i : i States District Court judge here in the 

This grand jury is federally im neied b a United 

Dii t&f Colun&a 

r31and were ’ conducting an investigation of possible violation; 

1 I1 of federal criminal laws involving possible perjury, 

[s~obstruction of justice, and subornation of perjury. Do you 

[6]understand? 

I71 A I do. 

181 0 Im ’ going to read to you from a portion of the 

[ glcqurj order authorizln 

I 1olthts IS from the Umt -eI 

a portion of our investigation, and 

States Court of Appeals for the 

I 11 IDistrict of Columbia Circuit, based on an application from 

[ 12 1 our office and Attorney Gene@ Reno. 

. 

7he Independent Counsel shall have jurisdiction 

I::land authority to investigate to ule maximum extent 

[ ISI authorized by the Independent Counsel Reauthorization Act of 

[ 1611994. whether Monica Lewinsky or others suborned perjury, 

[ 17lobstructed ustice. ‘ intimidated witnesses, or otherwise 

[I ~lviolated f d eral law other than a Class B or C misdemeanor 

[ I 9 1 or infraction. in dealing with witnesses, potential 

[ z o 1 witnesses attorneys, or others concerning the civil case, 

[2 11 Jones K C%nton.’ 

1221 

[23IyOU? 

Do you understand that portion that ILe read to 

1241 A I do. 

I251 MR. WISENBERG: Let the record retid that 

Page 6 

111 Q And who would that be? 

I21 A Stanley Brand. 

131 Q All tight. We are bound - that is myself, my 

I 4 1 wllea ues the grand jurors, and the court re 

[s 1 boun B ! 8” 

rter are 

- wrtt, certain exceptlons. were ’ boun by an oath of 

I 6 I secrecy which means we cannot gc out and blab what 

17 1 here today on the courthouse steps. we cant ’ leak it to t 

I B 1 media, we cant ’ talk about it. 

k 

ou say 

191 @ you_ understand that? 

[lOI A I do. 

Cl11 Q You, however, are nc4 subject to any secrecy. You 

[ 12 1 understand that. 

1131 A I understand that. 

I141 Q Whether or not you talk about it and how you talk 

1151about it isp%e_you and your attorneys. You understand? 

1161 I--, --. 

[I71 Q Now, Ill ’ give you an example of some of the 

r 18 1 exceptions to seaecy that is required of us. We can tell 

rlslcertaln FBI agents, who are on whats ’ called a 6E list. 

tzolabout what happens in the grand jury. We can tell them about 

rzllthat. 

Page 7 

Ill A Yes. Imso ’

r 

Yes. 

Q lftherewen obealatertrial-Imnotsaying ’

I:jtha!wDuldha~n,but1theremrrmrtokatrirl 

I 4 1 ansing out of Is invest’ ation, and you were to 

rsltrial and satsomething %fere% tiG$$ E$i, 

t6p+ could ta e your transcript a say. 

[7]drfferent in front of the grand jury.’ 

i ~~rule would be violated. But that would be allowed. 

And that would be an example of where the secrecy 

1101 understand that? 

Do you 

I111 A 

Q 

I understand that, yeah. 

I :$I inde 

There are also special occasions when the 

[ 14 I rule 

ndent counsels can have an exception to the secrecy 

avin 

t161law.“,y!u unde&dtha17 

to do with reporting functDns to Congress, and 

I wthose I be m, &II have to be author&d by a court of 

A I do. ’ 

- 

OlCStarr Page 1 to Page 7 
ESA 

3699 

George Stephanopoulos. 213198 

_~~~_____ ___- 

Page 8 Page 11 

I 1 lansffer. I might be able to give it to you by the end of the 

[2 Iday. But Ill ’ tell you that my understanding IS. with proper 

[31murt authonzabon. we wouM be able to - the independent 

[I 1 counsel would be able to either describe that in a general 

f5way or tum portions of it over. 

f 11 made my life a lot easier. 

i:icorrect? 

Q And we did not ask for any documents; is that 

I41 A That IS correct. 

151 0 

~6lconect? 

You understand that you cannot commit penury_ 

[71 A I sure I hope I dont. ’

181 0 Perjury is an intentionally false statement about a 

[ 91 material matter. You understand that. 

1101 

t 

Ri ht. I do understand that yes. 

I c#dnt ’ mean to sneak thatup ’ on you, 11s ’ just 

1:: 1 Ive ’ got my checklist of things Im ’ going to make sure you 

[ 13 1 know about. 

And I hope, finally, here in our ri hts and 

i ::i responsibilities -,and this is very im p ortan ?-thatif (161 theres ’ any ueshon that I or m 

fl6lwell ’ try to b! c&mar aKout it. ’ 

[ 17 IdonY unders and that 

col eagues ask that you 

ou wou d ask us to repeat it. and 

I61 A 

171 Q E?!will - I can get clarification for that by 

[ 8 1 the time youre ’ through testifying 

islwe can take a five-mrnute break - 

Or, if you would like, 

1101 A Theres ’ no need to take a break, but by the end of 

I 11 Ithe day. that would be nice 

- 

[1s]judgrnent of the prosecutor, is a putative defendant.” 

1261 

t211 

Do ~A”IJ ytzrstand that defindron? 

I221 Q 

1231 A 

You are not a target. Do you understand that? 

(241 Q 

I m very happy about that, yes. 

A sublect. w I& IS a much broader definition, is 

t251defined as, “A person whose conduct is within the scope of 

Page 9 

f 11 the grand jurys ’ investi 

4 

ation.” 

L21 at? 

f3I 

Do rdeT;;nd t 

[II Q As 

rsland. as a technica r 

ou can tell, thats ’ a very broad definition, 

matter. you are a subject. You 

[ 61 Understand that? 

(71 A 

Q 

I do, and is that analogous to “witness”? 

Well Im ’ lad you asked that uestiin, and the 

ItI next thing Im ’ goingto ’ te I you rs -in answer?0 your 

f~olquestion rs. an infonnal system has developed among 

I I I I prosecuton and defense attorneys, and the categories are 

t12rwitness. subject. and target. 

I::isomebody could technicall 

The reason for that is. subject” ‘ is so broad 

rlslbeing a target. or be some GJdv 

be a subject and be very close to 

that were ’ iust interested in 

[ 16 I as aivitne<s. 

So a more informal system has developed witness 

!:~~subject, target, with subject more or less bein 

(191is nol a target yet but the nod ju is certarn 

somebody who 

fzolinterested n-r headng from &em anymight h&some 

f 211 suspicions. LeCs put it that way. Do you understand? 

IZiand we just want information from them, no suspraon cast on 

Whereas a witness would be somebody just coming in, 

(24 jthem at ait. 

1251 Thats ’ the informal distinction between witness, 

Page 10 

151 Q But with that important qualification, you would be 

167 considered - YOU are considered bv us to be a wlness. Do 

tl7jyou understand? 

I 

I181 A Yes. 

I191 Q You are here today pursuant to subpoena; is that 

126lco~? . .,~~ ~._ 

I211 H Tes. sir. 

Q And we appreciate your a 

i::ishort notice. We appreaate the 

pearing on what was very 

tzclattomey. 

coopera t! Ion of you and your 

1251 A I appreciate you moving it up a day because that 

Page 8 to Page 13 

I191 A Yeah. 

1201 . .Q Okay? Is there anythin 

I2llf-e.S nsrbrktiis as a grand jury witness 

about your hts and 

t22lun r e&and? 

9 hat you do no n? 

I231 A No. 

(241 Q All 

[2slyour background. Fg 

ht. t wantto askyoua littlebtabout 

rrst. what is your current position or 

Page 12 

[l]tille? 

I$iartd Im ’ a 

A Im ’ a visiting professor at Columbia University, 

~litical analyst at ABC News, and t write for 

r4lNewswee 

t51 Q What do you teach at Columbia? 

[61 A Political science. 

171 Q Tell us where 

A ? 

ou were born. 

I81 I was born in all River, Massachusetts, 

I91 Q 

A 

And where did you row up? 

I grew up in Massac usetts and New York and 

;:?1]Cleveland. Ohio. 

9, 

[I21 Q 

A 

Where, in Manhattan or Upstate or - 

I131 r141S&KKll 

Steve and 1 went to the same grade school, Purchase 

L-.,---.--.. 

[ISI 

1161 

I171 

[I61 

1191 

[201 

1211 

I221 

I::&Jlobr 

1251 

Q All right. Where did you attend college? 

A Columbia Untversitv. 

Q And what was youipostgraduate work? 

A Oxford Univenrty. 

Q 

A 

Were you on some kind of a scholarship? 

I was a Rhodes Scholar. 

Q All right. What was your tieId at Columbii? 

A Poliil science. 

Q . Tell us about your postgr@uate. postRhodes 

’ e~nence. Did you then enter Into - 

Well, at Oxford I studled thsobgy. not polii. 

; 

Page 13 

[I 1 And then I went to Capitol Hill and worked for Congress for 

t2lseveral years. Also worked in the 1998 

t51for Michael Dukakii. Came back to the G 8 

idee$;dp- n 

tr]Congressman Richard Ge hardt from 1989 to l&l. 

I56;Arkansas. 

In September 1 & 1 I met Governor Bill Clinton of 

I moved to Little Rock worked for him in the 

;;;ygm 

96? 

ign. and then in the White kouse through December 31, 

191 Q What year did you first go to Ca itol Hill? 

I101 A The first time I went was 1983. P worked than for 

!::i& p 

ar-and-a-half for a congressman named Edward Feighan from 

IO and then I went to Oxford. Then I came bade and worked 

1131for 3. Fe. han again - 

1141 ?I Starting when? Do you recall what year? 

II51 

1161 

$ phyd time? 

(171 A In 9 ‘ 9 - fall of 1988 through the winter of 1988. 

[ 18 1 and then want to the Dukaki campa’ 

[ls]York for the New York Public Library, $ ‘

n. worked briefty in New 

ut then returned to 

12 o 1 Washington in the summer of 1989. where I worked for 

~21]Congressman Gephardt until September 1991. 

1221 0 And how old are ou? 

I231 A Nextweek Illbe ’ J 7. Im36. ’

I&91? 

C? So you didnt ’ meet then Governor Clinton until 

- 

OlCStarr 
3700 

George Staphanopoulos. 2l3138 Iyu(IJ) 

Page 44 

Ill A I may have shaken his hand one year before that, 

[21but I really met him rn Se tember 1991, yeah. 

I31 Q Okay. Te P I us about that. When and how did that 

, Id _ 1 , nl-x?, ____. In 

(51 A It was September of 1991 I was introduced by his 

i6jpollster. Stan Greenberg, and several other fnends. I was 

r,]mterviewing for a position on his campaign, and we hit it 

!s toff. and I moved to Little Rock. 

!91 Q This was after he had made ha official 

~~o~announcement~ 

:111 A It was a little before, just before 

I121 Q What did you do - tell us what your role was in 

er and communications 

rzzlthatfairtosay? 

i23j A _ Some people might argue - more or ksj, yes. 

1241 Q Okav. Was there a distinction between I 

~25jcommunications director and - 

Page 15 / 

(11 A Press secretary. 

(21 

2 

ress secretary? 

I31 &ich we had both jobs and - but I was - the 

1 I1 press secretary reported to me. 

t:;other than 

Q Okay. How many deputy campaign managers were 

I71 x 

ou? 

I dont ’ remember. I mean, at the beginning I was 

(8 1 the only one, but as the campaign got bigger, there were 

rg~more. 

I101 0 Who was the campaign manager? 

ill1 A David Wilhelm. 

[121 0 Would it be fair to say you had a very senior role 

I 131 in the campaign? 

I141 A -Oh, sure. 

Q Tell us about the transition between dam 

I:$Vhite House. Did you have any official role or unofficia P 

aign and 

rl7lrole? 

ilsi A Yeah, I was communications director for the 

t~gltransition. 

1201 Q 

A 

Okay. Andthatwas it? Thatwas1211 That was enough. 

I221 Q Okay. And, again, the press secretary would have 

tz3treported to you? 

1241 A Would have reported to ma. 

[2Sl Q The people who - 

I there 

I 

Page 16 

I11 A 

I21 

I31 A0 

Speachwriting reported to ma. 

~~&communicabons oflices. I had about 50 

[ 4 1 people report to me. 

Q 

li;got to the White House? 

All right. What was your first assignment when yw 

[71 A Communications Director. 

I61 Q 

isi 

Okav. Youre ’ vew consistent 

A VeGconsistent * 

[IO1 Q 

I 11 lreported you - 

The same kind of thing, the press secretary 

I121 

[I31 $ “:E:$Tc - 

[I41 A Yeah. 

1151 0 Then I understand there was a press secretary 

[ ~6 lstrictly for the local press, or somebody whose iob tt was to 

~17]cdmmunicate - 

IIEI Yeah, who did the local medii. 

t191 

$ 

- wrth state and kxxtl? 

,,?I, A YPL+ There was a b’ department. lt was about 50, 

i;;;52 people: ~Butl%ly~~ did _. that ._. until _. P __.._ une of -. 1993. ___. __ tt was ..__ 

[ 22 1 too much. And so I ave up that role and just was senior 

r23~advtser toihe P~r3s1 .Bent the rest of ml time there. C_._ a -_-II L ~__ ~~ . . . ,241 ” “nav. x7 rn tune or Y> vou aave up cnrnnnnxatn3ns 

iz5 jdiredor. 

Page 17 

Ill A Right. 

121 Cl 

r3lterm. 

Thats ’ just basically about SIX months into M 

A Yeah. 

0 And who took over as that? 

was - showed it was *& 

people, Des Dne MY=_ 

~~~~communications dtrector. Gergen was counselor, but the 

Dee Dee was press secretary Geaan was 

[ 12 jfunctions of my ob ‘ were split. 

I131 Q dkay. Then you became a senior advise0 So you 

I 1 I Iwere a senior advrser for three-and-a-half years. June 93 ‘ to 

~~s~December96. ’

1161 A Yes. 

! il i what 

Q 

doss 

I want to talk about - well. before I do that 

a sensor adviser do? 

A 

I::;- but the official title was Senior Adviser for Policy and 

It depends on the day. I was basically responsible 

t2 I 1 Strategy. fvly job was still workin on press strategy, 

;;;;&c$nmundrn$ reporters, helpq%oth devise and Implement 

on an presldenhal poltcy proposals. 

I would run various projects ranging in issues 

~~~~from gays in the military to economic L passage of the 

Page 18 

I I I economic olan in the Conaress to affrrmatiie action. I tan 

i 2 j the Presidi?nts ’ review of &%r&ve action. 

[31 I I 1 time. And 

It really did depend on what was goin 

P 

on at the 

I also was responsible. for better or or worsa 

[ s] for helping to respond to various crises that would arise h 

tslthe White-House; 

[71 Q Okav. Crisis response team. 

[El A Yeah. 

Q 

rio91 tell/r-g us, you were trying to help 

Would it be fair to sa that from what youte 

a ty leasi 

~i~~I$Lion? 

turn the 

ideas of the admintstraboninto ’ realjty. into 

0 

IE~other people with you? 

Yo&e not doing that alone. are you? Youva ’ got 

t241 

I251 

$ N~~yownoffice.itwasjustma. 

a? 

Page 19 

A ThanIhadanaasistant,crr~ 

i:idkt more or ksa exacutiva asaistantMcretarial work. I 

twn.butthey 

t3lkind of Roatad around. Im ’ not much of a ma 

I:;around? You floated - 

0 Youfloatadomund,oryouwou V finat-get 

161 A No, I floated arourtd. 

171 

191 AQ 

ts]issue. 

IEZad of managing a staff, I went fmrn isue to 

0 Okay.Giveusareal~briefksson6nwhatis ‘

i::i~backt+mundthepresa. YouaardyolJbackgrnund.aclthe 

1121 ress. ell us in a nutshell what that means o 

1131 ackground - 

A 

I~~~ontheracnrd,sornetirnasYsofftbamcord. 

It can mean two dirent things. Sometimes Is 

okay. And the diieranca between backgrand and 

[23,Off th4? ElXWd is? - 

1241 A lt depends on the reporter 

t2slBackgmund IS, generally what you say m *if . 

oura ’ talking to. 

be rdeMied as 

OlCStarr Page I4 to Page 19 
3701 

By\ George Stephanopoulos, 2/3/98 WAX(I) 

Page 20 

i I lone of a number of possible IDS - senior V&tie House 

I 7 ! official. White House official. senior administration 

ijiofficial: 

Off the record mean? one of two tilngs. This feels 

I:; like a journalism class but 

16! 

iTithing_ 

Q We do& haGee$h%-tuition. Thats ’ the areat . , 

!81 A Yeah, right. And the reporter cant ’ use it at all. 

[ 91 which is kind of a fiction. Or they can use the information, 

i 10 1 but cant ’ attribute it to anybody. 

[III Q Oka To an bod 

I121 A RighI. They lave!o sort of act like they thought 

113 1 of it by themselves. 

I ::;doin 

Q 

dl 

? 

Okay. And is that basical something you kept 

5 

rl6H%n 

I know it stayed as your official tit . but 

onally, you did more or less the same stuff from June 

[l?)Of 93 ‘ - 

A Many of the same things. But it would change 

I::;depending on circumstance as well,. 

.- I201 

[211 

AQ $YI~~.w, you sati policy and strategy. 

Q You were Senior Adviser for Policy and Strategy. 

:::;Did you apysY$yp that subtitle. “Policy and Strategy? 

1241 

[251 Q Okay. Now, I want to work with this map here. K 

Page 21 

f 1 Iwe can, and Ill ’ try to be as brief and 

12 1 Im ’ goin 

sinless as possible. 

to show ou what appears o be a map of the first 

t3lfloor of ti!e West &ng. ’ 

[II ‘

[51 

t Wstkretty good one. 

[61 A Most of the ones in the magazines have not been 

[71correci. 

Q Im ’ oin to put a sticker on a and mark it as 

[i;Grand Jury Exhibit%S-!. 

I101 (Grand Jury Exhibit GS-1 was 

[Ill marked for identification.) 

I121 BY MR. WISENBERG: 

0 Would you agree with me for the record that thats ’

I :: 1 what I have done? 

[ISI A Yes. 

Q 

ft161West Wtna? 

And that this is a map of the tirst floor of the 

iisj A Yes. 

IZperha 

Q And then. with the exception of what looks like - 

t/z 

you could hel 

II 

us - but it looks like over on the 

I$ ; %%Vest ‘ Terrace Lower Level.’ 

res ’ a portion at says West ‘ Tenace Upper Level” 

t231. A R’ 

P 

ht And I actually dont ’ understand what thii 

~2411s (indiitina). to ell you the truth. Ws labeled as 

[zs~“Room 110. 

Page 22 

Its ’ conceivabte that this is - 

[s tan area o;thisRyhqplat says, “Room 

I61 

(1 ‘ Q Is 9 hat correct? 

[El A Yes. 

Q And what youre ’ telling us is ttrat theres ’ no Room 

1 :oi ’ 110 that really is to the south of Room 111. b that corred? 

A I dont ’ believe there is. Th& to me seems like 

I:: :outdoor area. There would be the Preside& patii on the 

t13lfar right and the Chief of Staffs ’ patio on the far left. 

I::ioutside 

19 Okay. S? d theres ’ a Room 110. its ’ not . ht 

[lslis just d;e:~~~~~~~~~~;r~~~*~~~~~ ‘

; ; ; ; Complex; is that correct? 

A 

Q 

As far as I know, yes. 

I:Zisince you left. 

Okay. Unless theyve ’ like, you know, built it 

(211 A R’ ht. 

Q dii And Room 111 would be the Chief of Staffs 

r[::;office; is that corres? 

A Chief of Staffs office. and w to the right, 

I::ireception area for the Chief of Staff. Deputy Chief of 

Page 23 

:i: Staffs OffiCe- 

.T'! 

.-, Q Where it says 108? 

A 108, as far as I can tea Pm not real good with 

i: i these things. But then I think the ner, office was my 

:s!oftice. 

6: ‘

i-j 

0 Okay. 

A The? m 

; 6 j the Oval Office. which r 

office opened up into the dining area of 

hen opened uo nto a short hallway, 

! 3 lwhich had - if you were moving from my office toward the 

: 13:Oval. a bathroom on the left and a stucy on the right and 

: : ~1 then the Oval. 

il”] ia* Q Okay. What Im ’ goin 9 ‘ ask ou to do is pi& out 

i i 3 1 what youve ’ said .was your 0ff1~e an C? put a n&n there. 

Cl41 

i?5j 

~~Mb$n~sgaw&dt~ dcament.) 

1161 Q 

[17]cOm?d? 

Okay. And thats ’ just to the right of 108; is that 

[I81 A 

Q 

On this chart, yeah. 

[I91 On this chart. 

I201 A As far as I can tell. thats ’ what looks like mine. 

IZlI. Q Oka And if it% been represented to thin rand 

;;z;kx;h;;th$ ~~~c$f~rnPlex, ths room that says ttd, 

I241 

1.251 : Q 

Thats ’ as far as I know, yes. 

- you recall that you were just to the left of the 

[ 1 Idining room. 

A Yes. 

Page 24 

1151 Q Okay. And youve ’ put two 5% within the little 

[ 161 rectangle;; thveyrrect? 

1171 

[1B1 0 And thats ’ where your assistants would sit? 

t191 A Yes. 

t201 Q Then you said there is a safe against the - 

1211 A Far back wall. 

If&is area where yourassistants ’ sat, curred? 

Q Okay whatwecallthenorthwalltothefightof 

I241 

r251 

A Yes. 

Q Andthentheresthecbotwayintothedirrirgmom. ’

Page 25 

Q Okav. 

Q All right. And then you go through there to - 

i::lthere ’ appeers to be a doorway to a liile hallway - 

Page 20 to Page 25 
3702 

eu George Stephanopoulos. 2f3l98 UuysJ 

Page 26 

Ill 

%XR?Ct? 

$ Rght 

- on the othar side of the dining room; is that 

Okay. And whan you say We galley.’ ffiars also 

[24JSOflWtiWs Catkd the PntIy ff - 

1251 A Sure.yeah. 

page n 

111 Q Do you call it the galley? 

121, A Idontcalllt ’

Q AttrtgMAnd 

(f;thare*s a lii bfack 

=Fg. 

tts-whan usaynexttott_ 

JsJand then another whxe”” ‘’ 

to the rtght of tha Caplace 

araa. 

(61 A I think tt% the white area. 

171 

IsJ 

Q Thewhtteareaisthagalley. 

A Pantry.whatew 

0 

t$oth into y dini$ mom and out into the hallway 

Okay. NOW, ir W%<%o?laadinq fmm the pantry 

JllJ 

%ntp the haltway was that w&y dosad or open or dxJ 

Q Okay. Theckxxleadingfmrnthepantryroomout 

rl*Jthatdependon;vhethcrorno(thestewardswer;Ulcre? 

A 

r(%here, what was 

tt really depended on whether the stewards wem 

oing on that day. I saw both. 

IltJ 0 &ay. 

111)) A lt would be open and dosad during tha day. 

Kyou pan answ& 

Q lfthestewardtWWethenwasttusualtyrrpen,if 

A 

I22:linthaOvalOf8ca klwhichcaseYwwldbacfosad 

Gananlly open unbsss tham was a dignttary. say, 

123) Q tfhttmard+WWenattherebecaketheir 

124 J+nrices WefB IhOt needed, WQUtd it LlSUalJy be open of dosed, 

l2SJdyOU ft?Cali-? 

Page 28 

%XI had to. 

A -Generatlydosed,butyoucouklwalkthrough&# 

I3J 

141 

Q AtfrigM QiipeoplatypWlywatkthroughW 

A No. 

Page 29 

.-,- - -- 

161 

I?J 

(161 ?!“- 

IlSl~ 

tl7Jr#n 

Okoy.rightarOWdthismaindportntc,thadining 

;19i A Yeah. 

1191 a okpy. Doyounxatlhibastname? 

(201 A No. 

:22:;1 tMc I undeKt~ 

Q NrigM. Now,amctmeIrmwrong,butwhat 

l23JT utwsual for a n&% 

tosayaboutninequestionsagowas, 

;;:;* ata pantry. 0onecn 

tosanp~walkthmughthahakway 

A Cormu 

Page 30 

IBJ 

191 

A OrNatvts. 

Q Okay. 

A AlthoughGwanmcwathanNalvii. Iseamtommunt 

t2lJm 

1241 

i2sj 

%La 

lxtic 

-thaymightsitrtgMautsida.tb& . *{ r 

A ‘ TheymigMjustsitrightinIhcpantry. Thay a . 
3703 

BSA 

-___- 

George Stephanopoulos, 2l3199 

____~~ _-.__ --____ m--p- Xuu(S) 

Page 32 

[ 11 might go downstairs to do different duties. 

;:;0fiCe. 

Q And thats ’ when the President is in the Oval 

141 A Yeah. 

Q Okay whal if the Presidents ’ gone from the Oval 

iz;Office because hes ’ bn a trip or hes ’ gone for a few hours 

[ 7 1 somewhere? 

[8l A 

(91 Q 

Theyre ’ not around. 

Okay. 00 

A 2 

ou know where they would be? 

I101 I have no I ea. 

floor West Wing, I dont ’ - 

,- 

i25 jusually o-vn. correct? 

_ _ 

111 

121 

Page 33 

A Mm-hmm. 

Q Then down here is - 

131 A The study. 

Q 

$losed. do 

Thats ’ the study. And is that door usually open or 

x 

ou know? 

Usually open. Sometimes he would go in in the 

I;jmiddie of the afternoon and take a nap and close it. 

[El Q All right. But generally open. 

r91 A Generally open. 

[lOI Q If hes ’ in there. its ’ always - its ’ usually 

[ 1 I 1 closed or just for his nap, or can ou speak to that? 

LIZI A 

rl3lthere unless he calLi me in. 

Well enerally. rf 

’ 

e were there, I wouldnt ’ be 

il4j Q Okay. 

A So I wouldn? really know. Although there were 

i:z;tirnes when I had to get him I can remember the door would be 

[17lclosed. and hed ’ be lust tak;ng a na 

[NJ 1 him because we were late for some 

I:i!knock? 

Q 

f,_a; 

hn 

Id have to go get 

All right. Then you wou go up to that door and 

iZli 

I221 

(231 

rzclnap. 

1251 

A Yeah. 

Q 

A 

AU right. Can you tell us - 

I knocked because I wanted to wake Kin up for his 

Q Okay. Up to the north of this hallway is an oddPage 34 

11 lshaped thing, and it looks kind of like a map of Texas, a 

12 1 very strange map of Texas. 

(3lwhat it is? 

But, at any fate, do you know 

A I actually dont. ’ I mean I can tell you what I 

I:! remember of the hallwa . I rememberif ’ ou took two mom 

[ 6 1 steps comin from the 

[ 7 1 there would %e a bathim on the left. 

rnrng room past 

’ door to the rtudy’ 

ISI Q All ht So this would be bathroom up here 

191 

I101 

rdicai;$. 

I111 Q Okay. And that was a half-bath, or do you know? 

[::lthere. 

A I only went in there once. Yeah, theres ’ no shawer 

Q 

;::;a doorway 

Okay. And then ouve ’ got - you go right - have 

right into the Oval Of&e 

1161 A Theres ’ a door right io the Oval. 

1171 Q And was that usually open or dosed? 

1181 A Closed. 

I191 

1201 

I211 

I221 Q And the study is dsually open, you say. 

I231 A Generally o n. 

(241 Q All right. ili%k ’ ou to put an 0” ‘ there. 

I251 (The witness marked rhe document) 

Page 35 

i:; 

BY MR. WlSENBERG: 

Q If hes ’ tn there taking a nap, the President of the 

[3~United States, its ’ generally closed. 

I41 A I almost dont ’ want to Say generally. I know hes ’

I s 1 been in there - 

I61 Q Youve ’ seen it closed. 

i71 A Ive ’ seen it closed. 

I81 Q Okay. 

191 A 

I 1 o j both ways. 

Ive ’ seen d open with him in there. Ive ’ seen ~__.. it __ 

0 Okay, all ri 

I :: i bath there, in what you ca P 

ht. 

ed 

Can you justtut a little “8” for 

the bathroom. 

[131 

1141 & MR. WISENBERG: 

he witness marked the document.) 

1151 Q And this will remain a mystery room for now. 

1161 A I dont ’ think its ’ a room. 

ii7j Q Okay. 

(181 A 

r191it. 

Its ’ a wall. Its ’ got his button collection up on 

I201 Q Oka Button colleuion? 

A :::1] huge wall with - hes ’ been colle Yeak: he ~l~~$9$;;0;~i;~~t;ing I 

Q All right. Thanks. 

i::;else that Ive ’ forgotten that I might ask you later but - 

rzsland lhen 111 would be typically Chief of Staff; & that 

I1 IcOrred? 

Page 36 

.-.-- ~~~ 

I21 A Yes. 

131 Q Room 111 on this map, all tight. 

Youve ’ toM us where you sa1 when you first came 

i:iinto the White House and you kept that oftice where youve ’

161 got the “G$” th:ewF[e time you were there. 

I71 

181 Q Is that correct? 

I91 A Mm-hmm. 

I:;;oftice? 

Q Was there any partiilar reason that you got that 

A I was a dose adviser to the President, and I 

i::l]worked wtih him a lot. 

Okay. Access. 

[22i A Yeah. 

I231 0 MacMdartywouldhavebeeninlll? 

A Well Mac - Leon Panelta for most of the time. but 

if:iMac McLarty start&g. 

x 

Page 37 

IS1 

161 

[71 

181 

[91 

1101 

1111 

an 1 

Q Is that correct? 

under 

il2i 

1131 

II41 

IIS1 

1161 

071 

0 And 

A Righl 

ouve ’ put an HI” ‘ there, amect? 

Q And who would be in the room to the leR of 106.’ 

rlelhis - 

A 

!:~~Pahniiri John who was Harolds ’ a&star& J&e was in 

Its ’ all the assistants you know Jennifer 

[ 211 Harolds’offiqe ’ with ’ him. There was a second assistant back 

122lhere (indic#mg . 

A nd 

i::&atween 108 and 111 correct? 

“here” is the bottom right corner of the office 

1251 A Right. There ‘ s ’ a desk here, Jennifer Palmieri. a : 

Kg-Page 37 OlC-Stan 
3704 

ESA George Stephanopoulos, 213198 

~- _~~_ .___~ ~___ __ _____ 

Page 38 Page 41 

[I idesk here. drfferent people at different times. a desk here, 

(2 I enerally. thus guy John, who was Harolds assistant, but 

[ 31 % rfferent people at different times, a desk here for a 

iI1 0 

~2 1 addition to the other 

Okay. ~~;~ght. And that would be a desk - in 

131 A Two 8” esks. There would be a desk here a desk 

j 4 I receptroriist (markin 14 I here, a desk here. and iust an area here where the TV was 

And then w 

). 

I51 ere were oflen - there was sometimes 

I 6 I another desk here or here with phones, and sometimes interns 

[ 7 I would be at one of these two desks or that desk (marking). 

[El Q Okay. And am I correct that you’ve drawn bastcally 

[ 9 1 about five desks - 

ilO 

Ilil 

$ About five. 

- in thus room between 108 and 11 l? 

Cl21 A Right. 

Q And would it be fair to say the 

/ : : i assist bothAthe F;$!f of Staff and the Deputy 6 z 

are peo le who 

hief of taff? 

(151 

I161 Q 

[ I 7 1 the 

Okay. However, Mac McLarty and Leon Panetta. if 

r~e~furt t; 

start walking throu h doorways, they cannot get any 

er than 108. corm c93 

ii9i A Correct. 

[ZO) 0 

[211gOttogooutIf theyre ’ heading towards the Oval Office, e 

1221 $ gkiyThe 

& 

have to go outside. 

I::;you started if you know? 

o was the other Deputy Chief of Staff when 

1251 A Erskine - 

Page 39 

L11 Q Okay. 

A 

IllYeah. Erskine Bowles. and then he left, and Evelyn Lteberman 

- and then Evelyn. Oh, wait. Is that right? 

[4lbecamede uty. 

I51 8 And thats ’ under Mac and Leon Panetta, or were 

[6)there other peo le before that? 

A gh lets ’ see The first deputies were Ro Neel 

I ,’ 1 and Mark Gearan.’ Then it was Phil Lader and Erskine E&lWles. 

[ 9 1 Then it was Evelyn Lieberman and Harold Ickes. 

I101 Q Okay. Can I ust ‘ ask you to hold on for just a 

I .~~. I I I second. Rov Neel and then t ark - 

I121 A. 

1131 Q 

Roy Neel and Mark Geaan together. 

Oh, Mark Erin? 

[141 A Mark Gearan. 

[151 Q 

A 

Gearan. Im ’ sorry okay. 

They were under Mac. I think Roy was the first one 

;:76;to leave. Then it was Phil Lader and Erskine Bowles. 

1181 

I191 

0 All right. 

A 

Izolgetting the - 

No, I m - they all held these jobs. I might be 

Page 40 

0 Okay. And ouvementionedtheoffice ’ of Harotd 

1:; Ickes. who was a Deputy CKief of Staff, 108 

*r 

ouve ’ put an 

: 

I 3 1 “HI.” Where did the afternate Deputy Chii o Staff hang 

14 lout? 

(51 A Over here marking). 

161 Q Okay. An d 

171 A 

youveputan ’ xthere? ’

Q 

That would be Evelyn Liabemran and Erskine Bowtes. 

Oka 

i ii for the grand jurys ’ L 

You have an “EL’ and an “EB.” And that is. 

nefit - there are two rooms beneath 

tlolthe lobby, and you have marked “EL” and TB” in the right 

[I I 1 room; is that correct? 

I121 A Corred. 

Q And then their assistants would have been in the 

’ ~::l]room to the left of that? 

i 

A To the left and also the Presidents ’ assistants 

/:65iSteven Goodin sometimes sat there, Andrew Friendly Rebe&a 

! 

(17 ~Cameron. This was a floati 

“9 

desk at tii (indicating 

You should also no e that before Erskine ha 

~:~~office, Bmce Lindsey had It. 

d.. thus 

I201 Q Okay. Andrew Friendly, Steve Goodin, and Rebecca I 

[ 2 I 1 Cameron, correct? 

I221 A Yeah, and also - I forget her name. She went to 

r23)Justice. Andrews ’

i 

1241 That wou 9 d 

rrlfriend. I dont ’ remember her name. 

be a rotating office. A bt of people 

tzslwent through that office. 

f5i 

b 

marking). ’ 

Okay. Youve ’ drawn three desks - Im ’ going to 

/ T;show them to the r+ran$ury - a desk in the upper left of 

[ 8 1 this office to the le of rskine Bowless ’ office a desk to 

[ 9 1 the upper left, to the upper right, and then kind of in the 

[ 10 1 lower right, theres ’ a desk, correct? 

illI A Yeah. 

Q 

i::lshow it to the rand urors. 

All right. Im ’ going to take just a moment and 

I141 MR.GIS&NBERG: Does anybody want a closer look? 

I151 BY MR. WISENBERG: 

1161 0 Now. is this okav if we kind of do it between the 

~17jtwOOfUS- 

[181 

1191 ?I sure. slanted like this? 

1201 A Yeah. 

Q All right. Bruce Lindse was in this office at one 

r:: ’ Itime. the office where youve ’ put the -E 

t23)now you put a “BL.” 

L” and the “EB.‘ and 

[Z~location? 

Where did he end up going to in terms of office 

Page 42 

Ill A I think the second floor. 

(21 Q All right, in the Counsels ’ Office? 

131 A Yeah. 

Q Oka . Hes ’ also been at various times a counsebr 

i:;to the President is hat correct, or a member of the 

t6lCOUnSerS Office? 

r 

A 

Ii;official title. 

Sure. Well, Deputy White Counsel, I think, is his 

Q Oka 

I :i jleading from your o 

Was there a door in the area - either 

L 

~11 ldinin 

ce to the dining room or from the 

rlz)peep?3ole in it? 

room to the hallway. was there a door that had a 

A 

i::;office and the dining room. 

Yeah, there was a peephole in the door between my 

t151 

1161 

2 $Xa$ It would be right here (indicating). 

1171 Q A door that was usually kept dosed. 

I161 A Yeah. 

0 

I:Zianybody in there 

R’ ht. And, I take it. that;s to see if theres ’

I211 A 

1221 Q 

[231 A 

Y!??r?~~l&~?~&~ iyyyay, but - 

Now, whywouldn you go a ing rn 

Q 

You Just dont ’ barge in on the resident 

I&ere, correct? 

okay. And you never know if hes ’ going to be in 

A 

i:iwere in the middle of something where he knew I went that 

No. And I would oniy go through that door if we 

131way. or if be called me in on his ohone. 

Q 

I would have lost the offir if I did. 

IZfrom 

Okay. Now is there also a peephole on the door 

Betty Curries ’ area into the Oval Office? 

(171 -A Yes. 

tlsl Q And that is - +a way in from where Betty Currfe 

[ 19 I sits, thatsplconsy$d ’ the marn way, rs R not - 

(201 

I211 

- WI 2 Absolutely. 

- th>t most people would go into the Oval Qffice? 

IZ;yourself. 

Q Okay. Even including very senior people lie 

1251 A No question. 

OlCStaK Page 38 to Page 43 

- 
3705 

BSA 

Page 44 Page 47 

;1 Q Okay. 

.-. 

l-the only wty to get intb the Oval 

I mean basicalty. thats ’ really - thats ’ really 

I mean it would be 

,< -a!most inconceivable that someone would just walk throu h my 

: 5 -office, unless i8l 

: 6 -the President. 

they were tn the midst of some business w 

- and its ’ just one 

(13: everybodys ’ goin back and forth. 

meeting where 

fl4: 

115: 2 ?$?A a little different. 

(16: Q Mac and Leon did not, as 

11: :through your office and through the back 

a general matter, 

way. 

II@: A Absolutely not 

119: Q And neither did you. 

120: A Ri ht. 

Q 

~:::typical hours but w at would bs 

O&at What were - and there might not be any 

[23ia crisis of some type, what ww d 

our typical day - banin 

be your typical day at t a e 

[24:b%ite House? 

125: A Generally I would get in around 6:25, 6:30 in the 

Page 45 

12 r1~momin8 ~for the 

because it was my job to go through the newspapers 

res4dent before he got in and before our staff 

;:;~trngs,~d ~+d~~1~~ve&~~~~30 p.m. 

15: A Yes. 

16; Q 

ttjanivsd. 

So you would typically arrive before the President 

[81 A 

Q 

Oh, almost always. yeah. 

I91 And you would Leave after he left, generally? 

110: A Generally I would wait around. Sometimes he 

t 11 ;stayed. but that was - a lot of us who were kind of hi 

[12;pemonal staff would wait till he left unless he was staying 

tl3:all nght. in which case I would go home. 

Il4i Q Did the President ever cell you at home at night? 

I151 A Sometimes. 

t24lmrJmIng. 

I251 Q Okay. 

Page 46 

A But to call after 1130 would happen if we were in 

i:],the middle of somethin 

Q Okay &t 

f :jmoming. after midmght 

basicafly the wee hours of the 

I s~thrse-and-a-half years 2 

db you m&l - you were there 

I61 A 

Q 

Very few times. 

I71 

181 A 

Very few, okal _ 

Cl 

You know, de nrtefy less than five. 

t!z&7 the President. 

Somethings ’ up tf you get a call afler midnight 

A 

~~~~morecallsaftermidnig t anIdrd,maybenotal& But 

Definite~ $sah. &w, Pm sure Leon probably got 

ti2lgenerally midni ht was around the - 

Q 8kay. I take it fmm what youve ’ already said, you 

i::ididnt ’ as a general matter, feel t+ea to walk in on the 

[16]Pn&knt UnannOUnced. 

A Definitely not. No, definitely not unannounced. 

I:iiPartofm obwereif-youknow ‘ iflwassittinginmy 

r~s#fice at X-l 5 In the afternoon andCNN ’ went lie with an 

rzopxplosion, you know, from Oklahoma C‘ 

% 

I was relied on 

I 2 1 ~generally to be the person to qr5ckly get rngs moving, so - 

t221- thats ’ as close to unannounced as I would get. 

But I would run around the corner. quickly tell 

$:iNancy or Betty - 

1251 Q Okay. 

Ill A 

Q 

- thrs has ust ‘ happened and - 

121 And even 1 

r3rentrance. 

hen, youre ’ walking “rough the main 

141 A Oh, yeah. 

151 Q *Okay. And youd ’ say, “I gotta go in them 

[ 6 1 SomethingAbg ;;z 

[I ‘

f: 

,pened. 

tijthis door 

Q All right.. Which leads me to trr neti question. fs 

- when the Presidents ’ in the Oval csiF;ce, is the 

i 10 1 main entry door usually kept open? 

1111 A Closed 

I121 0 Okay. 

[131 A Now, every once in a white, whsn he was first 

[ 14 Igetting in. or just before he was read 

I151 open, you know. when he was sort o 

to leave t would be 

r Paclung up his desk and - 

1161- .- ~, 

El1 ’ i_ke sometimes if it was toward the end of the day, 

tlsland the news was just done and everybodylranted him to go 

1191 home, and I woufd go in and just tell hrm quic%+y what 

r2o)happehed on the news to kind of hurry him atons. 

t211 Q Oka 

r22 1 than at that door? fiat is?he door that - 

all ri ht. Can I ask you to put a “C” them 

1231 

1241 

pM$tt&r$r@@e doq4Jme4.U 

r251 ; 0 Okay. And thats ’ the door from where Betty 

Page 48 

I 1 I Currie - could you put “BC” where Betty Cur+ would sit? 

121 

r31 

pM2tg$;$43 document) 

[41 

151 

161 

I71 

181 

191 Q 

A 

And that goes to a hallwa conact? 

I101 It goes to a halfway, then L! 

I 11 I Roosevelt Room. 

ads knuards. the 

30. 

il21 Q Okay. 

A 

I::lcorne meet him. 

That s where the foreign leaders would generally 

I151 Q 

,lLI 

L--1 A 

yzhforeign leaders would come at the 11:00 door. 

. __... 

I171 Q All right. Let me ask you about the study the 

I 10 Istudy door. Was there ever an occasion where that studv door 

il9iwas~c@ed.where 

;;;;“at dimArm r E d 

w~q E u$walked ‘ i no matfer 

I221 Q Anbwhyisthat? 

A tfthadoorwasclosed,itwasforareason. lt 

iiiimeant he r eybly sleeping. 

r 

Page 49 

Now, if we were late for T,Mq&x&bty 

leads into this little hallway that leads 

---__- 

Page 44 to Page 49 
3706 

George Stephanopoulos, 2/3/98 xhlAx(9) 

Page 50 

11 ]might be going from his desk to the study and back and forth. 

Cl Okay. Lets ’ say that it were closed - and I dont ’

I:;know if this ever happened to you, so thrs might be in the 

[4 ]realm of a hypothebcal. But lets ’ say this door were 

rs]closed, and you needed the President, and you thought - 

[61 A I would knock on it. 

(71 C! 

[ 8 1 open this door. 

You wouM knock on it. Again, you would never just 

[Yl A (Shaking head.) 

[lOI 

1111 

Q All right: 

A Because this - this area is considered his - even .--, 

I 12 ] private than eve hmg else 

(131 0 0 x ay. 

A This hallway with the stud 

/ ::) basically. its ’ the only lace the Presiden fy 

and the bathroom. Now, 

P 

can be alone is 

[ls]that little bathroom or he study. 

Q All ri ht. So this -would it be fair to sa - 

i : 1: i if I asked you what 

Of tt! entire &hite House is riaht hereng- ’

e most rivate area of the West 

,191 A .--, 

[201 $dic&ing). 

._ 

Of the entire White House. and you were pointing to 

I::lthe study, the hallway, and - 

1231 

(241 Aa The -and bath-. that bath. Okay, all rioht. Now - 

1251 A Becauseitsth ’

Page 51 

El Q * Okay. And thats ’ always been understood the whole 

(31 time you were in the White House? 

A The whole time I was there. A 

Izidifferent under Reagan. Apparently Michael & 

parentiy it was 

aver had an 

[ 6 1 offce somQwhegkt7 there, but - 

(71 

(81 A no r when we were there. 

Q &xv if we were to get - youve ’ identii the 

[ji;rnost private kind otroom and hallway and bathroom. 

I111 A Right. 

Q If we were to move out in a broader way spatially 

i::ifrorn here, within the West Wktg which is the - the West 

1 I4 ] Wing is considered - anybod iith an office in the West 

[ls]Wlng, thats ’ a neat thing, righ r7 . 

1161 A 

ii7i 

Its ’ verv unoortant. rioht. 

I . _ 

[ISI 2 

Q 

%%idered very important. 

i :i; like a more aeneral area - vouve ’ identified the most 

All right. But even within the West Wing, is there 

-_____-- 

OlCStan 

Page 52 

I 1 loffice, thii comer (indicating) - 

[21 Q Okay. 

131 A - is considered the Presidents ’ suite. 

I41 

2 %$e all interconnected and 

winnow. people - since Be 

%ar 

s office, Stew& a III 

ou just - yeah. 

[ 7 ]kind of a reception area 

I 8 ]for a meeting. But the&d 

[ 9 1 of the other offices. 

s where you wou$cE% 

be no other reason to 

Q Okay. Could you ask you to draw an arc - is that 

I:iiwhat youd ’ call it? - from what youve ’ called - oh, how 

rlz]about this? I got a liile highlighter here. What youve ’

[ 13 1 identified as kind of this - 

f141 A Its ’ the interconnected Oval office. 

1151 

1161 

~~$ine;;?e~&d&e document.) 

I171 

1181 2 %!?the cabinet is connected as well, but thats ’

11918 liile different. 

i2oi Q Yes, okay. 

I211 A 

rzzleither 

And depending on 

in or not in - 

how YOU consider my 0-t itk 

.--, 

I231 

r241 

[251 

4 - Oka bu r it% connected, so its ’ in. 

Q All right. Now, does that also mean that youve ’ - 

- - 

Page 53 

]I Ilet me just show the rand urorr. ‘

121 MR. WISE#BER& 

[ 3 ] you all see? 

I dont ’ know how well vellow - can 

I41 A JUROR: No. 

(51 MR. WISENBERG: Okay. 

I61 

I1 ’

~I-ii~lT~~T~~G: Is fig?bie to get water? 

181 THE WITNESS: I11 ’ wait fn/e minutes. 

I91 Thank you. 

IlO1 BY MR. WISENBERG: 

1111 Q And thats ’ another important thing I need to tell 

],x]ike a break, let us know. 

[ 12 I ou. If you have a health emergency or something, and youd ’

uess what Ill ’ call an arc. 

area weve ’ been 

- not as much. 

Page 54 

A 

i:;especially when the 

Althou h there are. as I said uniformed guards, &I. . . 

resident LS m there 4 you cant ’ just 

[3]hang out On the other hand, if I have v&k to do, I would 

14 ]talk - you know, if the Secretary of Treasu 

t s J he was with his dep 

.% 

and we ran into ea zl 

came by, and 

[ 61 haltway. we mi ht stt 

other in the 

ere and talk for tie minutes 

0 

fiithat haliwa to 

%ure. okay all right. People are gdin to use 

~9]theChiifoVSt&sofficein lllet from - ybu know, if you had to go f?om 

1101 A 

iiij 

To the Roosevefl Room. 

Q Or the cabinet nxxn. 

i::!to the Wh& House or youre ’ going to the 

- or the cabinet room or if ou were going over 

(141 Q All r;srht. 

balil5.j 

I:$apk 

IlBl 

A - thafs ’ not that unusual. 

Q All ht. Youve ’ got kind of like-youve ’

likeASecz&%vice agents, uniformed and not - 

il9j Q Afleast some Sec.& Service a ants. 

A Usual 

i:i!right outside the Ova ? 

the uniform&there an 8 thenonuniformed 

Q 

t::~Oltice. and uniformed - 

Okay.. Nonunifonned is right outside the Oval 

i::idining room. 

A Ismorebetweenmyofficeand-rightoutsidethe 

Page 55 

Ill Q Qka. Andtheyksepaneyeondoorsleadiihto 

r21thii private duster Lre 

131 A 

Q 

Any doe; leading into the Oval is uarded. 

Okay. Can you tell us - and ma 

~&st question before the break. Can you tell us c 

thiswillbemy 

-and 

[61bs as expansive as you want here - what. in general, wem 

[7]the role-well, youve ’ talked atmut the stewards. I thmk 

181 How about valets and aide-de-camps? 

A 

%camp is general 

I consider those different things. The aide-de- 

&’ 

- It was Steven Goodin or Andrew Friendly. 

.I11 2 An&at was - they oollected the Presidents ’

~$iefcase they took stuff they traveled with him they 

[14]canied h&pa 

fe 

rs. 

11sldocuments~ 

Theic+ed morefiis oft&l 

(161 

h&~~kts camed more his clothes and - 

i17j A - tatin 

Q 

care of hi as a pemon. 

i$before. and you mentioned that 

All righ? Youve ’ menyaE Frr;dty and Goodii 

(201 A z 

Q 

They did have a here, too (indicating). 

l211 In the office next to Enkine Bow&. 

- (221 A 

Q 

But they also had a desk here (indicating . 

I231 Okay, but they also had a desk in the Be lly cwrie 

czrlarea. 

1251 MR. BARGER: Thats ’ two questions, Mr. Wwnbefg. 

- 

Page 50 to Page 58 
3707 

Geome StephanoDou1o.s. Zl3l98 IyIX,,OI I-. 

____ -_._ ..- ~________ L_.-__ 

Page 56 

!:1 MR. WISENBERG: Were ’ taking a break. 

::j tlauYteri HE OR 

/ : i the witness ma 

PERSON: 

be excused. 

Okay. itll ’ be ten minutes, and 

;51 THE tv ITNESS: Thank you. 

!61 MR. WISENBERG: Thanks. Well ’ come get you when - 

171 THE WITNESS: Great. 

L-j 

[?] A Right. 

Q The Evelyn Lieberman room, at one time Bruce 

1 :i Lrndsey room is that correct? 

15: A ’ Yes. 

[61 Q All right. And then the valets perform a similar 

I 7 1 function, but its ’ more social, like helping him get dressed 

[a 1 and that kind of stuff? 

19i A 

11 o 1 his daub kit. 

Yes. They would o et his ties a clean shirt, 

I think the best way 7 o #rink aboutit is the 

[ 11 rarde takes care of the President and the valets take care of 

[ 12 1 the person who is president. 

Q All right. Would it be fair to characterize the 

I :: i aides as relatively low level ernpb~ees but who have a 

I I 5 I remarkabl$ leveio~access to the resident? 

(161 

[ll ’ Q 

rlelpeople. 

Obviously these would have to be very trusted 

fgi 

fsivd. WISENBERG: 

rtness excused. Witness recalled.) 

;3; Let the record reflect that the 

f I CI !witness has reentered the grand 

I understand, Madam 

.ury room. 

+ oreman that one of our grand 

i :iijurors ‘ wasnt ’ feeling well and had to go home, but that we 

[ ; 3; still have a quorum. Is that correct? 

1141 THE FOREPERSON: That is correct. 

1151 MR. WISENBERG: And there is no unauthorized person 

f16lin the grand u ‘ room is that correct? 

I171 TdEr%OREPERSON: No sir. There is not. 

MR. WISENBERG: All right. ’ And have you remtnded 

::89;the witness that hes ’ still under oath? 

I201 THE FOREPERSON: Yes, I have. 

I211 BY MR. WISENBERG: 

Q Mr. Ste 

I%;the same George Step !I 

hanopoulos ust ‘ for the record you are 

anopoulos &o has been testiimg here 

tzrl~this afternoon? 

I251 A Yes. Can I just - 

Page 57 

Are 

S;IE FOREPERSOf? ’ Yes. 

ou both art of the rand jury, then? 

THE WITNESS: Okay. 

Now, we were talking about stewards, valets and 

MR. BAPGER: okay. Thank you. 

Page 58 

111 BY MR. WlSENBERG:. 

Q I think we were starting to talk about the fact 

I fi before the grand jurors made me stop and take a break that 

14 1 Mr. Gooden. 

rslisthat-aret 6 e calledaidesoraidedecamps? . 

ou mentioned, even though these aide de camps - 

161 A ?hey ‘ re ’ caked the Presidents ’ aide. 

I71 Q Okay. Its ’ like an aide de camp, is it not? 

181 A Yes. 

Q All ht. The would be-even though they had a 

1 :i;desk in the area to “3, t e left o fy where Evelyn Liebermans ’

tlljoffice was - 

ll2I A 

iiiihere. 

Rioht. If the President is in the oval, thevll ’ be 

Il4! Q 

A 

Okay. They!1 ’ be in the Betty Currie area. 

If he s not or rf the 

::651doing some other ctean up work 

re havrng lunch or just 

Q And where the 

t :i {kind of like due north of Be 

$re$ll be over here. 

Ii be hes ’ in the Oval Office is 

t19: 

A Nexttothe~&ieagainstthatQ Next to the N. Against the back wall, up against 

i:y;the cabinet room wall is that correct? 

[221 A Ri ht. R ‘ ht. Mm-hmm. 

Q Al?right. ?&d if hes ’ not there if the President 

t::iis in the Oval Office youve ’ already identii@d the desk in 

fzilthe upper right-hand comer of the room next the Erskine 

r19i. A Yes. 

Q Can you tell us where the President spent most of 

~~~~his time when he was in the West Wing? 

1221 A 

r231or in meetings. 

Most of the time. it was n the oval, at his desk 

(241 Q And thats ’ the Oval office. correct? 

[251 - A Yes. 

Page 66 

[:laides 

Q Who would you say when you were there of all the 

t3lthe most time wrth Presaent~t~~~~~)lnknn~~~~t ‘

and it might have cha 

[ 4 J it to aides, I mean secretaries. what hava 

. 

A Well, it really woutd cha rnge’ a lot. I mean. Leon. 

i z; there were times when I spent a lot of tirite with him 

I 7 I Erskine. as far as Harold. the Vi Presider ~_ It asfaras 

i e j senior assistants, but Steve Gooden was with him 

I 9 I lot of the time and Betty and Nancy were always in Th . 

ou know, a 

at surte 

i23j -_ A Right. Idontlovathatcom~arison. ’

I241 

t251 

G 

Page 81 

James Baker for Ronald Reagan. 

James Baker for Ronald Reagan. Is there - the 

IS1 Q 

I76;Niion 

A 

Oka . ‘ But maybe not quite as close? 

I do rhink Hakteman was exceptional. I think 

- as far as I know of history. and Im ’ teaching this 

t 8 1 now Nixon didnt ’ spend much tine wtth an 

[ 9 1 Ha&man and Kissinger. Clinton is very d #!rod 

Y except 

erent. He 

tlo~spendsalotoftimewrthaktof 

0 Okay. All right. &Tz?“. was it that determined 

i::laccess to the President when he was in the Oval office area? 

(131 

1141 

“0 lz;ti$ Nancy. 

4 

1151 A Hemreich. 

1161 Q AndsheisinthisI171 A Thisliileoffice hthere. 

Q 

IZ:Qval Office. 

Theofticethats ’ Trnd . ofsetoff duenorthofthe 

__._ __ ---__ 

Page 56 to Page 61 OlCStarr 
3708 

George Stephanopoulos, 213196 

__.._ -- 

Page 62 Page 65 

: : , know is not a problem, I might ask Betty, but Betty wouldnt ’

:~:generally. I think, do It without - tf Nancy were around, it 

3: would be Nancys ’ call. 

Q 

.5 j functions? 

All right. And they just have slightly separate 

.6j A 

.-I, Q 

Well, Nancy is Bettys ’ boss. 

Okay. Is there any reason, then, that Betty is 

:a icloser to the actual door to the Oval Oftice? Thats ’ just 

: 31 the way they set, things up? 

::I] 

.--1 

Aa Igktst the way they set things up. 

::2j A And IJ ancy had her own office. Betty was more 

::3joutside. 

4’ Q 

i ;5 i Hemreich? Is that 

OkaX. How would you describe In a nutshell Nancy 

A 

ow you pronounce It? 

I would call her the Presidents ’ executiie 

i::;assistant. She worked for him for a long. Ion time. 

I : 8 1 Imean, back in Arkansas. She took care of i? IS personal - 

~15lschedule of a lot of his friends, a lot of his personal 

tzolpapers. kxecutive assistant is the best I could do. 

Q Were there differences in what you described in 

i::itenns of detenninina access to the President? Would it be 

iz3jdifferent at night or 6n weekends? Was there more taxii? 

A A little bit. Saturday momin 

? 

s was a liila more 

if:l]relaxed. Generally, Nancy would come in rom her run. I 

[II BY MR. WISENBERG: 

Q Can you make a distinction between the pre and 

j: jpost-Panep workin environment? 

I41 It tigh 9 ened up more under Panetta. 

I51 Q How so? 

A He was in much more control. It was - rather than 

1:; having people of relatively equal rank. I mean Mack was a 

[B 1 relative weak historically chief of staff. Leon was a pretty 

tsjstrong one. and thmgs were more centralized through Leons ’

[1010ffice. 

Ill1 Q Okay. What about .ust in tens of the forma&y of 

[ 12 jwho would be allowed to walk into i he walkways around what 

t13lyouve ’ ldentttied as the privacy cluster with your yellow 

tirlmarker? 

Page 63 

A No. Although son% doors may be tire open. 

i9 

ii0 

[II 

112 

ii31 A - unless the President is in the West Wing, in 

j~rlwhich case its ’ close. 

:151 Q All rioht. Thats ’ what Im ’ callinq the 11:oO door. 

&%Z%al Oftice. correct? - 

Page 64 

!:(determinina the access. shes ’ schedulina aaendas. doina 

isischedules.“or is that 

A 

&nebodyelse? -- - 

Well its ’ different. You know theres ’ an Off& 

I;iof Scheduling, which is a hu e job. I mean ihats ’ -thats ’

1 R lessentially scheduti 2 the &te House and all the 

t9tPresident s travels. ut she more micro-manages his personal 

j:o@tedule. 

I111 

lIZI A0 

I131 

AQ 

;::;know. wee8 to 

iffiwithin thatihe 

I151 

I191 a 

Okay. Wtiin a broader schedule - 

A broader overall schedule. 

That might not be - 

Shell ’ like more manage his day as opposed 

month, year. 

Theres ’ a broader schedule she doesnt ’ set, 

!ZKZrZs inside it Yes. Yes. 

Qkay. She has input to it. 

to, you 

but 

I201 

1211 

A Oh sure. 

MR. Wl$ENEERG: Lets ’ hold on a minute. I hear the 

izjdoor. 

I231 

rJ;““““-A R. Wl ENBERG: Let the record reflect we heard the 

i::fdoor jiggling, but nobody opened it. 

Page 66 

Q Somewhat. Oka 

[: i to himself during the workday? 

Did the President ever have tkne 

15. 

r33that for him? 

Id you all try to provide 

A And more and more over the course of the four 

~:!years. we tried to provide it more. It was caked that phone 

[ 6 1 In office time. 

Is this time where people dont ’ bother hi unless 

[ IE 1 he wants to be bothered? 

$~~th?ll ‘ buzz 

A R’ 

tzlland some&es ’ 

ht. And he sits behind hi desk and som&nas 

ou on be phone and sometimes hell ’ take a nap 

0 

hetl ’ read. Whatever he wants to do. 

i%ieitber T let me ask you this. .Either 

Okay. Now, within tha are you saying that 

wibinthatphonein 

;;:;&~a~&~~$$lel%th$;~ p=&JE4=h_ he 

Page 67 

I I Iwants to take a nap. where hes ’ in that study area? 

A Is usually within that time. but theres ’ no 

i:ipartiarlar time. its ’ whenever. 

t4t. _ Q Allright. Anddoyouknowhawbngthatusmlly 

ISIB7 

A 

176itook a nap it would be 20 minutes. haban hour, like 

its ’ not usually. I mean but -you ‘ know, if he 

I 8 1 anybody else. 

0 Okay. What kind of people had access to the West 

t El Wang in general? 

A 

;::;You had to be 

People who had hard passes 

pre 

% 

much a senior assistant ’pennanenthad 0 the Prestded - 

t131or the -generally lowest level unless 

I I 4 1 m the West Wing was called special assts 

ou had an office 

+a nt to the 

I 1 s 1 President. whii k like lower middte management. 

::76iwhat? 

Q Run that last part by me again. Unless you had 

A Unless - you know Steven Gooden the aide, is not 

!:!!a speoial assistant to the Presideni. but thats ’ whe& he 

[ZOJWOrks. 

$lWtng - 

Q Unless you happen to have an office in the West 

1231 

: Right.0 

I::lperson ’ to be in the Wes 

- you re oing to have to be a pretty senior 

? Wing. 

_ 

OlC-starr Page 62 to Page 67 

- 
3709 

BSA George Stephanopoulos, 213198 

Page 68 

Ill 

121 ii z?:;. 

A But, 

[:istuff. things like tha Y 

ou know, other junior people could deliver 

51 ‘ 0 Okav. Be in to make deliveries and thev would have 

r pass atso. is that correct? 

[ 11 time it may have come up is in the job of the Presiinrs 

Page 69 

(2 jaide, generally ht that wouM be a man. 

Cl 

ople tho 

@cay. I thix you said one of them - one of the 

i : 1] ones you mentioned was a female, correct? Rebecca Cameron? 

I51 A 

Q 

But she wasnt ’ - she worked fpr Nancy, I think. 

(61 

17 1 ou mentioned her des 

[II 1 r hat Steve Gooden and Andrew Friendly used. 

Oh, oka!. Att Tht. You menboned her being - 

berng he same desk that you thought 

191 A Across. 

1101 Q 

!iljlm ’ glad I - 

Oh, shes ’ across from there? Okay. Atl rioht. 

A And I dont ’ know. This one might have been hers 

!i:;and this one mi ht have been his I dont ’ know. 

1141 Q &~re. Okay. But ihey were not the same desk. 

Ll51 A No. 

1161 Q 

A 

And they were not the same - 

1171 There were two desks in that room. 

I181 Q 

I191 A 

Okay. And she was whose aide? 

Q 

I thought she worked for Nancy Hemreich. 

Okay. You had said that name earlier and I wanted 

::!;a clarification on that. You said that wouldnt ’ have been 

(22 1 your job. Whose job would that have been? 

A I don? patticulady accept the 

i:fiit was never discussed in my presence that ?r=ri= knew a’ 

. ttsjthe deputy chief of staff, there was - Evetyn and Erskine 

;; iwere responsible for,management of the White House proper. 

Q AndImnotaskingyoutoacceptthepn?mrse, 

t31blrtL41 A Yes. I dont ’ partioularty. but - 

151 Q Butiftherewas,theywouldbethepeopleI61 

171 A0 Yes. - who would handle that because theyre ’

1 B 1 operational deputies. 

[91 A Operational deputies. Riht 

Q 

I:ijis that correct? 

And, again, they werent ’ deputies at the same time. 

1121 A No. That slot was the o 

Q Now. Im ’ not saying tha p” 

rational deputy. 

we have. but assuming we 

i ::i have heard that there was this tssue. this appearance issue, 

I I 5 I youre ’ not in a position to say. no, thars wrong that never 

(16jreaiiy happened, youre ’ jUSt not aware Of it 

1171 A 

Q 

Im ’ not aware of it. Right. 

i18I Okay. How many interns were you aware of in the 

[ 19 1 West Wing? In general. 0-r a grven day, how many - were 

120 1 there a lot of interns. a few &ems? 

A The whole West Wing or the 6rst &or? I couldnt ’

I:: jspeak to the whole West Wurg. 

I231 Q Yes. Im ’ sorry. The first floor and specifically 

(24)the general areas weve ’ been talking about 

(251 A It depended. You know, genetatty, you know, at 

Page 68 to Page 73 

- 

Page 71 

[ : !various times I had two pard staffers or one. If I had only 

,: !one paid staffer, then I would generally have an intern man 

[ 3 lone of my desks to answer the 

s 

hones. So I would 

14 shave one to two around. This 

enerally 

uster of offices wou P d 

;sigenerally have between one and three around. 

Q 

i-P;Ickes’ office 

This is between the chief of staffs office and 

!81 A The same thing here. One or two here maybe. I 

ls!would expect that there was probebl 

r~o~office, none rn the Nahonal Secunty Lf 

one or two in the press 

I dhe Vice Presidents ’

Ice, maybe one in 

,--, 

Q A% then 

I::;but you were pointing to &e 

ou mentioned - you said the word here, 

area left of Erskine Bpwles’ 

t1lofhce as an area where you thou 

Page 72 

ht there were some interns? 

I:iaround. 

A Every once in a w 8. ale. there might be one or two 

Q Oka 

i:;they be over in the 8 

Would that be their main office or would 

[ 61OVer OCCasiord ? 

ld Executive Office Building andcome ’

A de last couple of weeks have been in part an 

il{education for me. I just didnt ’ think about interns a lot. 

[ 9 1 Imean, I would see 

[lotI sometimes wouldn gee 

pb around, but I didnt ’ know who - 

know who was paid and who was an intern. 

[Ill Q Okay. I guessA 

I::&, a cou 

There were - yes. there were, you know, a couple 

le there, a couple here. 

I141 8 All right. I guess what Im ’ trying to find out is 

t1sldrd you have -and you mght have not. apparently based on 

1161 

r 

our answer, thus mrght not have been something you adverted 

(17~oatt.hebme.butwerethere-didyouhavethesense~1 

rven day as youre ’ waUcir-19 down the hall you coukl see 

or ten Interns going through these hallways weve ’ been 

It just wvou#nt ’ be something I would think about 

1231 

t241 

1251 

Q Youcant ’

A I real can 

. x “S”k to it. basically. 

Q Allng 

f 

Page 73 

Do you know where Laura Capps went after she was a 

A She became a staff assistant for me. 

otcstarr 
3710 

BSA George Stephanopoulos. 2l3/98 XNAXHfl 

;. 

Page 74 

Q Okav. Do YOU know if shes ’ still at the White 

i 2 i House? ~ . 

A She was up until December, but her father, a 

i:lcongressman passed away in December and her mom is running 

: 5 ;to ‘ replace him and so shes ’ gone back home to help her. 

i6l Q 

; 7 I President? 

Okay. Did the interns generally have access to the 

;a1 A Not general1 

Q All nght. 

You would see them in the. halls. 

01 1 er than on ceremonial occasrons. 

: 1,; ‘ were there ever Interns in the - for instance this area 

i: I i we’ve talked about, the Oval Office, study, dining room, 

I 12 iother than on ceremonial occasions, would there ever be 

i 13 j interns in those areas? 

Like I said there were - sometimes one-of my 

hones if my assistant was gone. Every 

s another office removed. 

P 

h its ’ within your 

ice. 

Okay. You never saw an intern there than you can 

Page 75 

1 I1 remember;theh;han on a ceremonial occasion. 

I21 

Q 

i:iPresident? 

Have you ever seen an intern alone with the 

I51 A No. 

161 Q Do you know Monica Lewinsky? 

i7j A Yes: 

(81 Q 

A 

When did you first meet her? 

191 

tlorshe joined 

I cant ’ tell you. Im ’ sure it was some time after 

the White House. 

1111 Q Do you remember the circumstances under which you 

[lzlmet her? 

1131 A I think she was answering hones in this duster. 

1141 Q 

A 

Okay. YouLe talked abou P the cluster - 

I!51 Between Leon and Harold. 

0 Oka 

i :7”; ou met her or she 

tIsl&islative Affairs?’ 

And do you know if she was an intern when 

ad already gone to work for Office of 

A Couldnt ’ tell vou. Could be either one. but I 

i;oidont ’ know. 

. 

1211 Q Do you remember the time period that you first saw 

tzzlher answering hones in this oftice? 

A $es Inthelaattwoweeks Ivereadamilliin ’

~::~timesthatshestariedsometimein-IgubssYSandworked , 

j 

rzslthrough96,sothatwouMbethetineperiod,butI- ’

Page 76 

[II Q You dont ’ remember based on your om - I 

I21 A I wouldnt ’ necessarily remember it based on my ! 

t3jown - 

[Cl Q Yes, thats ’ what Im ’ asking you right now. based on i 

tsjyourownA And I just shoutd sort of have a blanket statement 

it i now that youre ’ asking questions about her, for the last hv0 

, B Iweeks, because of m new ob, ‘ my new responsibitiii. Ive ’

[ 9 1 read everythia$$t&s$e; tryrng very hard here to 

floljust speak to 

I :: jof do ‘

Q Yes. Unless I make it clear that Im ’ askirg kind 

ou know have you heard’ questions, Ill ’ operate 

.--, I I 1 I under r hat assumotion. 

I141 

1151 

A RighL 

0 But if you - its ’ possible that certain events in 

tls]the last few weeks -: 

1171 

Ilfll t !%d%?%%!%%e%% with reswd to - .--. 

[191 -A A liile bii. %is. I 

Q Okay. Can outietbef~rsttimeyousawbertoa 

~:~~particutar event. if not to a J ate? 

c22lgoing on. 

To something that was 

i 

A The only one I remember, there was some - 

j::isomebodys ’ birthday or something. Often when theres ’ - like 

tzsjmy birthday or someone else that the President knew, we might j 

Page 77 

; ; 1 have cake in Betty and Nancys ’ office. 

121 Q 

~3~pWiOd? 

And you think rt might have been around that time 

I41 A Could have bean. I cant ’ tell you exactty when. 

:51 Q 

[61 A 

A very vague memory of that. 

Q 

Vague memory of it. 

r i i cluster of oftices 

Do you have any memory of her working in this 

i 51 chief of staffs o ffy 

ouve ’

ice? 

identifed to the right of the 

r:o: A 

I:?] Q 

I .ust remember her answering the phones. 

Okay. Do you remember if that might have been 

t:z~during any of the budget - 

A 

1:: 1 the budget was one of my major responsibilibes. so that 

Probably. Thats ’ probably why I remember. since 

[ 1 s 1 would make sense. 

Q All right. Is there an 

;:76;fimt time you met her? Any part& rar ’ thong that stands 

hrng memorable about the 

118lOUt? .--. 

1191 A No. 

I201 Q Do you know where her - youve ’ said that you saw 

12 11 her answering phones in the room to the nght of 111. 

122 1 know whez shfd;Ft.regularty bcated - 

Do you 

r231 

i24i 

2 No. 

- at that time? 

1251 L 

[II 

Page 78 

Q Did you have contact with her either when she was 

I 2 I an intern or worked for Office of Legislative Affairs on a 

13 1 regular basis? 

A 

[:;jogged from reading it in one 

I wouldnt ’ say that. No. Again, this memory was 

azine thus weekend. I think 

[ 61 she would lrke bring me cotfee. ?3 ut I think my assistant 

her and so I would never really see her. I woufd 

~i~$%%& that the coffee was there. 

0 Okay. Shed ’ stop her from actualty getting - 

i:iiher. 

A Some is even - yes. I would have e0rr& contact with 

i$iwas her re utation 

g” Dti{o$ny her by reputatiy? And. if so, what 

A an during the time 

I211 Not rea 

122 1 attention to interns. 

_ I mean. again, I didnt ’ pay that much 

Cl 

IZ~ber in the West Win . 

Obviously from what youre ’ telling us y0u did see 

1251 A Mm-l?mm. 

Page 79 

;:;she! - 

0 During the time period, lets ’ start about befon 

i:;woutd notice that I woi~td have 

A lmean I-letmust-youknow,IguessI ’

a&ee 

[ 5 $efinttel 

[6)a lot to J 

wouldnt, ’ you know let this &!~o~n~?%%rd 

o. I wouldnt ’ think about 

Q 

~~~tl-ris person in? 

Okay. Did she ever tell you why she wouldnt ’ let 

[VI A No. 

1101 Q inj Have vou ever heard the term clutch? A d&h? 

A Sure. - 

[I21 Cl 

A 

Okay. And whats ‘ a clutch? 

A clutch is - welt. another word ia Velcm. 

~:&omeone who just seeks to attach themself either to a senior * 

rlsjstaffer or the President. 

Q 

I:76;reputation? 

All right. Do yar know whether or not she had that 

A 

:$&ink about it then. 

Now Ive ’ read so much that - yes. but I didnt ’

1201 Q At the time, you diint ’ know that. 

1211 

[221. A Q Notreaf? Okay. 

r23lu-r the West Win 

o, again. rts ’ fatr to say you did see her 

1241 A dm-hmm. 

1251 Q If you had to - before the tii period that she ’ . 

_-- -- 

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ICA 

3711 

Georae Stephanopoulos, 2KV98 _- “_A ~_ ~. _ ~____---~__ ~- -~--_ -.__ _ 

Page 80 

[ 1 lwas removed from the.White House, if ou had to quantify. if 

;; 1 

t; 

o&could. how many bmes do you .g thin you would have seen 

r, Tnf _ 

Page 83 

A 

2 

For me, yes. yes. 

I thin\. but don t hqld me - 

rsliob. so - 

I didn t have many lobs. though. I only had 07e .~. 

I41 

151 Aa %Y? 

161 A I dont ’ know. This is so loose - a dozen. 

171 Q 

c 8 1 President? 

Okay. Did you ever see her alone with the 

191 A No. 

(101 0 Did you ever see her enter the Oval Office. the 

[ 111 study, the;allw$ off the study or the dimng room alone? 

[I21 

Q Let me define alone. When I say did ou ever see 

I :: i her alone with the President. that would mean in a SI .r uabon 

rlslwhere she and the President were in a particular room and 

[ 16 1 nobody elz wai;y that room. 

Cl71 

[It31 0 And you didnt ’ see her alone with the Presideilt. 

I191 A No. 

1201 Q 

[z 11 based on what 

Okay. Do you know, did you know back the?, ndi 

K 

ouve ’ learned in the last cou 

[~ZJYOU know whet er or not she was ccnsidere 8 

le of weeks, dtd 

a good intern? 

1231 A Didnt ’ think about it for hatf a second. 

I241 0 Do you know how she got hired permanently? 

[251 A No. 

III 

[Zl 

171 

Page 81 

9 !T Office of Legislative Affairs? 

; ; ; she aot hi&-l? 

A NO. 

Q Okav. Dii vou know or did vou hear at the time how i 

/ 

i5j - A No. / 

Q Have you heard since then how she got hired 

I ,” i permanently in Office of Legislative Affairs? 

181 A Actually. no. Id ’ like to know, to tell you the 

i 9 j truth, but I dont ’ know: 

i20jhn intern? - 

A 

;::;to be good. 

I would say - the latter question, yes, youd ’ have 

1231 

A" EY&an I could imagine - it was cyclical. 

[::~Youknow,wehadthestaffart ’ Iwasafwaysfightingfor 

Page 82 

[31for me to be able to argue. you know, Laur;! and Staca were 

[I 1 here. you guys saw what a 

~51 talking about, you know, $1 B 

rest job they drd, were ’ on G 

,000 and were ’ working 90 hours a 

[slweek. I need some help. &J its ’ a combination of necessity 

[ 7 1 and talent. 

! i i aty 

Q 

E 

ical 

Okay. Now what about the first art? How 

Ram one 

[lolto t 

or how typical woub it be to go 

e other, intern job to paid staffer. 

straight 

,111 A I think its ’ deftnitelv the exceotion to the rule. 

i ;; i but I couldnt ’ quantify it. ’ ’ 

I131 0 Okay. All right_ Do you recall if you saw her 

A I cant ’ quantify it I probably had in m 

I :Z jexperience 35 interns over the course of four years, 

own 

x0 

I 17 1 interns and two ot jobs. 

II81 0 +wo out of how many? 

[I91 A Thirty-five or 40. 

1201 0 Thirtv-five. Okav. If voure ’ standard. if voure ’

;;;jpar for the course -’ 

- * . 

A I dont ’ know. I should say I dont ’ know that Im ’

I::lpar for the course and I didnt ’ deal with management, so I 

(24 1 wouldnt ’ know the whole - 

I251 Q Obviously less than 10 percent for you, two out 

uILE14) 

___ 

. . 

Q Do you recall whether you saw her more or & 

176;gafter she went to Legislative Affairs from her internship 

reljob? 

A 

l :z;answeting 

I assume I saw her less because she wasnt ’

hones on the first tloor. but I dont ’ know that. 

& Did you ever see her with the President - ycnrka ’

i $ I]said you never saw her alone with the President did you ever 

t 13lsee her with the President at all that you can re&ll? 

(141 A Well, probably that arty, that first time. 

1151 Q 1. 

llslarea? 

Okay. The party w ~ch was in the Eetty Cum 

I171 A Yes. 

Q All right. Other than that, did you ever see her 

I:iiwith the President? 

[201 A 

[21]not then. No. 

ILe seen her in a lot of pictures since then, kr: 

Q All 1 ht. 

:::iback thenif se+zsy ?le r even in the room with %e President? ’

Thats ’ the only memo you have from 

I241 

1251 : 0 And anything unusual about that event? 

Page 84 

111 A No. 

Q You never saws her alone with the President in any 

I:ilocation, not just the ones Ive ’ talked to you about, 

[4]corred? 

151 A Right. No. 

Q 

17”; reason to believe the President wouM later be or iust had 

And you never saw her in a room where you had 

i6 jbeen. 

I 

191 A No. 

0 I take it then that that means - and I realize 

IElthese are sensitive questions, so Im ’ going to be as genteel 

(~z]as I can, Im ’ going to ask you a few uesbons about a sexual 

r13lrelationship which will include both i 4 ercourse and oral 

I 11 ~sex. Do YOU understand? 

il5i -A Yes. 

Q And I take it. then, you have no personal know&&e’ 

!:$hat she ever had a sexual relationship with the President, 

rl8luxect? 

1191 A Correct 

Q 

!%let me break it down. Before the last - 

Have you heard from any source whatsoever - well, 

.~-~ 

1221 A No. 

Q IwanttotalkaboutbeforethiibecameamaW 

IE&ent in the last couple of weeks. 

1251 A Right 

a 

Page 85 

I might have heard a rumor so& time late tast 

176iyear. just in the air, but that would be more from the 

I 8 I loumalistic area. more from the Newsweek thina. Nothinc 

i 9 j-tien I was there. 

[IO1 Q You cant ’ recall who you heard that rumor from? 

Ill1 A No. 

0 Have 

i::irne go back, you thin P 

u heard anythin from-inotherwc&,let 

that would have %ee n 

[ 14 1 rumor you heard in late last year? 

a journalistic 

A 

IEiremember exactly. You now, R was sort of in the air in the 

Late last Lear. yes. Mid tolate. I dont ’

[17lfall. 

1181 . Q 

[lglthmk? 

All right When you heard that, what dii you 

I heard bts of rumors and I diint ’ think about L _ 

Page 80 6 Page 85 OlCStafr 
Page 89 

Q 

If 1 from your years at the White House, thats ’ an unusual 

But in your vtew. based on your up-dose knowledge 

I 3 1 circumstance 

BSA George Stephanopoulos, 2/3/98 

~~~ _~___ ~-_ XWW - 

Page 86 

ill A Correct. 

Cl Have you heard anything in the last cou 

I;jthat leads you to believe, from an source, that she ha 

le of weeks 

[4 asexual relationship with the Prest .J ent as Ive ’ defined it? 

s a 

A 

[Sl A Do I have to answer that? 

Relatively unusual. I would sometimes - if the 

Q 

[;iwith that - 

Yes, but you can feel free if you have a problem 

I: i President, if I woke him up from a nap and he was changing, 

161 uttin 

~7) P coul 9. 

on a new tie before an event and I was briefing hrm, 

[El A Id ’ better talk to my lawyer - 

rmagrne betng alone rn the study with him or making 

0 Go ahead. 

LB 1 phone calls, but its ’ not a normal thin 

(91 

A - because I have these journalistic 

[91 Q He would have to inv ip e you in, of course, Is that 

[lOI 

[I I 1 responsibilkies. 

flojcorrect? 

1121 Q Sure. 

1111 A Definitely. Absolutely. 

Q 

1131 A And I dont ’ know what - I have to do deal with 

Lets ’ take somebody in Ms. Lewinskys ’ positiin. 

ildjthat. 

[::iShe was an intern and then a relahvely low level staffer in 

MR. WISENBERG: Thats ’ right. Thats ’ why hes ’

114 lQffrce of Legislative Affairs. 

1151 

flslhere. 

[ 1 s 1 of your knowledge? 

Is that correct, to the best 

1171 Well ’ take a brief recess. 

Cl81 

(191 

B”,b~~recec~~~&en.) 

Q Youre ’ the same Geo 

iiijtestiiing Fce;e;g, approximately, ?t 

e Stephanopoulos whohas ’ been 

.45? 

1221 

I::; 

Q Im ’ goin to go back for a minute. You had asked a 

8 

: 

uestion earlier about (e). exceptions to 6(e) and matters 

i23 j unusual if she was alone-on several occasions with the 

rzslt ril at get sent to the Hill, d you recall. 

[ 24 1 President in the study? 

I251 - A Ithinkso. 

1161 A Yes. 

[I71 0 That Ive ’ properly defined what she was? 

LIEI A Yes. 

Cl And then after that, she had a position, some kind 

i:oiof ’ a position at the Pentagon, is that correct? 

1211 A So Ive ’ read. 

I221 Q Somebody in that kind of a position. would it be 

Page 87 

I151 A Fine. 

1161 0 Is that understandable? .--. 

1171 A Yes. 

Q Okay. Let me see where we were. I think I had 

f :iiasked you - we were at a “have 

rzojwant to ask you, let me ask 

(21 Ilast couple of weeks when t 

fzttthan the one thing you talked to us about that you heard in 

t2stthe air last summer, have you ever haard from any source that 

t24 ]the President and Ms. Lewinsky had or may have had a sexual 

tzstrelationship? 

3712 

Page 90 

Q 

I:; that level would be alone several occasions in the Oval 

And would it be unusual if a person such as that at 

f3lOffice withAthe yPFresident? 

[41 

Q I want a clarification. Your invocation of a iz ijournalistic privilege is limited at this point to the last 

I . 7 1 couple . of weeks. rs that correct? 

A 

Iiiextend that. Ive ’ been undir contract to ABC since about 

lt.is. I mean then we should - I might have to 

[ 101 last Janua 

r3 

. I have to check with them. I have not talked 

r11jwith the A 

r12j 

C lawvers. 

0 

A 

YOure ’ going to talk with them? 

I::;would believe that 

Im ’ oin to talk with them. I would think they 

ax! e ends since I left the White House 

tlsiand signed a contract with them. 

1161 0 Which was when? 

Page 88 

Ill A No. 

i<lfrom -. 

Q All ri ht. 

m generally w 

In the last two weeks. have you heard 

e last two weeks or since this has 

14 tbecorne a public issue, have ou heard from any source that 

rstthe President and Ms. Lewins r, y indeed may have bad a sexual 

fsjrelationshi ? 

I On that, I have to daim privilege. I am a 

!i ;oumalist ‘ now em loyed by ABC News and I dont ’ think Im ’ at 

19 Iliberty to answer #at. 

Q Okay. And we will not at least for the time 

I: y Ibeing. we were ’ not going to litigate this issue fate in the 

il2 jaftemoon. 

-_ - 

A May I just make a note of that so I can tell ABC 

I::lwhen I go back what ust ha pened? 

1151 fvJR_ WlSEkBERCS): Yes. 

G 

Page 91 

A Yes. I11 

0 

i:ito the ABC 

All rfght. You and your tawyer are olng to tak 

leandcornaupwithaposition,I % kert. 

I41 Ape%& isi 

AQ &rig&f lawyer represents ma ior my time in the 

${White House and I have to check with ABC for my employment 

re~with them. 

Q In light of the most recent allegations and Ive ’

t:o; ’ kind of askad this questipn in a sliihtfy diirent way: is 

IstZ%Z~~IF?~ Kz%%?K & to 

would~l be a journalistic 

1161 

I171 KX?W~SBNBERG: 

Q 

f:ilthe President. would that have been unusual. ir your visw? 

If Monica Lewinsky had been akme in the study with 

i2oi A I think so. 

_ 

I211 0 

A 

And why is that? 

It would be unusual, I think for anyone - a ain, 

t::inot unprecedented but unusual for an one to be alone in 

[24]study with the President, I believe. B u! again. fm ’ sure he’ 

tzsjcould be in there and I just wouldnt ’ know. 

A No. 

Q . 

i:iiwith Ms. Lewmsky. Just something in terms of the 

it wquldnt ’ even have to be stnnathin&at~saw 

. (22 1 or the layo: ori: event. 

1231 

0 Okby. Now is there something in the last coupla 

I::iof weeksthat youve ’ heardfrom any of your sources that I _ 

Page 86 to Page 91 
3713 

- 

George Stephanopoulos, 213198 

Page 92 

: : :makes an event in the past take on a new significance? 

.-. 

.-. A I cant ’ answer that. 

--.. 

.-, Q Youre ’ invoking that journalistic privilege. 

:i. A Yes. .5: 

frj Q We just need to make a record for that. 

A . 

.-.. Q %%vay if we need to it can just be litigated 

.s ; at a later time. instead of marchina vou in to answer the 

i?iquestion. 

“. 

..?I L-L. 

[.:I 

$ p$go back one questjon. 

A This may be nothing, but I just thought of one time 

i i:i I saw her at Starbucks and people come up to me all the time 

! 14 iand she came up to me once and it was like one sentence about 

r~stdbes the President tell the truth or somathing. I suppose in 

t16,retrospect - at the time, I didnt ’ think anything of it 

r171becaUse 

$ 

ople come up to me and say thin 

4 

s like that all the 

[ 18 J+.im. bvt suppose if yoUh3 ’ Stretching. that t at at SOme - 

tlsjlevel could have new significance. 

12Oi Q Ms. Lewtnskv said that2 

i211 

(22; 

1231 

I241 

r251is - 

A Mm-hmm. _ 

0 

A 

Do you know when? 

It was some time late 96. 

Q Okay. Is that-was that like unusual? I mean, 

Page 93 

No. Its ’ not unusual for people to cdme up to me 

(161 A Sure. I saw her. Yes. 

0 Okay. Do you remambersaein 

t:i;outside of the White House, then, occasionally 9 

her - I mean, 

t19i A That would be the onty place I ever saw her. 

r201 Q Okay. You had no soaal relationship with her. 

i2lj A No. - 

Q Okay. So you might hava seen her a few times at 

:z;the startnJ+. __ 

t241 A Yes. 

[2Sl Q When she cama up to ydu. it was if she was srxne 

Page 94 

[1,wh0lcnew ou? 

121 K Evervbddv comes UP to ma as if thev know me. 

t3 jAnd I certainly recd@ized her. 

Okay. Agan. at tiiht oftha recant a;vtipns. 

Yes. 

Q 

f : iis there anything you have seen or heard in the past t at IS 

I 6 I consistent with a sexual relationship between Ms. Lewinskv 

j 7 i and the President? 

191 A No. 

Q 

t:iiin any way about any relattonshtp. social or sexual, between 

What. if anything, did the President ever tell you 

(111 himself and Ms. Lewinsky? 

I121 A Nothing. _ 

Q And I take it based on your earlier answers that 

I ii 1 ‘would be true of anyone else? 

I151 A 

Q 

Yes. I was his staff, Im ’ not his peer. 

Okay. Did you ever discuss while you ware at the 

I:76;White House Monica Lewinsky with Batty Currie. to your 

r191reaAlection? 

i19j A I dont ’ think so. 

IiyiJordan? 

Q Did you ever discuss Monica Lewinsky with Vernon 

(221 A No. 

I231 Q With John Podesta? 

I241 A No. 

l25! Q Wiih Leon Panetta? 

ill A 

I:1 

t31 AQ 

141 

I51 AQ 

161 

[71 

181 iii 

(91 

Cl01 t 

[ill 

Cl21 t 

1131 A 

[I41 

I151 

I161 

Page 95 

No. 

With Bruce Lindsey? 

No. 

r;th Evelyn Lieberman? 

Wtth Bayani Nelvis? 

Who? 

Nel. The steward. 

Oh, Nel? Oh, no. 

With Harold Ickes? 

No. 

Wrth Erskine Bowles? 

No. 

With Hillary Rodham Clinton? 

No. 

Wtth any other White House staff rnembefl 

[I71 A No. 

1181 Q Do you know wh 

[ 19 1 happened, not to the events of t K 

-letsgobacktothetimett ’

e last few weeks, do you 

rzojknow why she was kicked out of the White House and sent over 

t21tto the Pentagon? 

c22j A- No. 

Q 

t::;whatsoever? 

You heard no rumors about it at the time 

1251 - A No. 

Page 96 

Q 

I:! have a consciousness that she had left the White House? 

Did you ever know that she was gone? Did you even 

t31 A I dont ’ think so now, you know, but I dont ’ think 

rr1so. . 

[ISI Q Are you aware of any other White House intern or 

[16]Office of Legislative Affairs Staffer who Vernon Jordan /’ 

I 17 I personally~odk~~~sea an attorney? 

I191 

~:~~Housa 

Q Do you also find based on your time in the White 

our knowledge of pdlitics. that event to ba 

rzltnsmarka % le? 

A I found a lot of things at tha white Howe to be 

~$ernarkable. Thii is - its ’ going to take a bnger answer. 

124 I Its ’ not. inconceivable to me. I mean. unfortunatety, you 

t2stknow, rf you would have asked ma four years ago WCMJ# I ever 

ST 

Page 97 

tllimagine spending SlOO.WtJ on lagal bills and dorni 

t21 rand ury ‘ four times I would have said thats ’ nma 

to a 

t3#3d. Aese are unu&al times. So even thwph irs%t** 

14 lsomething I woukl think is necessarily norma I cant ’ say 

tsjthat in my experience its ’ so dut of thts world that I 

f 6 1 couldnY rmagine it. 

Cl All ht. Thats ‘ not as remarkable as all the 

f: i individuals I named “3,. 

191 youre ’ saying? 

elprng her to find a job? Is that what 

A 

~:&ild even imagine - 

it depends on the circumstance you know? And I 

I 12 ~could Laura have had k 

ou know, if you tell ma Laura Capps. 

at sama ltne up help hef? Sure. But 

t131its ’ remarkable. I mean its ’ -you know, its ’ - 

.--, 1141 BY MR. BINHAK: 

Q Is another word for remarkable unwuaf? Would it 

Ii65l)also be unusual? 

1131. A Yes. Its ’ unusual but not unprecedented. I mean, 

;::;” - it hat%%. TER: 

Q But OU JUSt rtWltidned Laura CappS and kfdm y&t 

~~~~~~~ that her fa her had been a congressman, is that 

.__,_. ~.. 

I231 A Yes. Oh, yes. 

1ZiMr hat? 

Q Is that one of the things that makes it possible 

_____- 

Page 92 to Page 97 OlCStalT 
3714 

BSA Georae Stephanopoulos, 2/3/98 Xyu(IlT) 

Page 98 

A Well. what makes it possible for her is that she 

j: iworked for me, I liked her - I mean, thats ’ what Im ’ sa ing. 

[3]lts ’ ossible. Laura did a great job. If she was going or 

co)? jog, I would call r*le and I would call - I could ’ 

1s ] rmagrne calling Jo n odesta. Bill Richardson, Vernon Jordan 

[ 6 J to help her. 

[I ‘ BY MR. WlSENBERG: 

Q 

I ti is that correct? 

She moved into a permanent staff position for you 

A Yes. Thats ’ right. 

Page 99 

11 j Laura. for exam le. I can see things like that happening. 

t21 BY M&. WlSENBERG: 

Q This rumor that was going around about a week ago 

i:;about an event witnessed in a screening room in a White House 

1 

tstby -there are different variants of the rumor, a Secret 

: 1 

[ 6 1 Serwce agents - / 

171 A 

fi;in a corn 

Q 

A whole bunch of them. Rtht. 

Where somebody saw Ms. ewmsky and the President 

I loltoumalis P. 

romising position. Exduding your period as an ABC 

.--~~ . did vou ever hear - 

(111 G ‘ *Never heard it. 

IZjWhite House? 

- anything remotely like that when you were at the 

[141 A No. 

Q What if anything did Monica Lewinsk 

I::labout any relationship she had &ith President Clinton y? 

say to you 

A Nothing. The on 

i:ilhis name was that encounter at %le 

ta&l;;&eard her mention 

Q 

~:~~directly indirectly stated or imp red to you tha she had 

She never in an)! way explicit~ implicitty, 

.~~_ 121 ~such a ielationshio? 

t221 A Nd. 

Q Did she take an action that fed you to believe she 

i::&ht hav;a re$;ionship with tXe President? 

1251 

Page 100 

Q 

i:iof at the time? 

Did she ever give hi any gifts that you were aware 

t31 A 

Q 

No, not that I was aware of at the time. 

[:iis that coned? 

Those are all gifts youve ’ learned of since then. 

161 A Yes. 

0 Do 

Ii;Clinton usia rnN”,9 r hat said Santa Monica? 

ou ever recall seeing a mug, seeing President 

I91 

I 

%ffiCe? 

Q Do you ever recall seeing such a mug in the Oval 

121 A He had a bt of mugs. 

131 9 OF?y. Did the Presdent ever give you gifts? 

n T es. 

Q He was in the habit of giving staff members gifts? 

A Mm-hmm. 

Okay. Based upon what youve ’ learned from 

i::)published sources since then, did she seem to get the same 

[ 251 attention as other people at her staff level? 

Page 101 

II1 A No. 

12: Q 

r3lsay? 

Considerably more attention, would it be fair to 

14! A 

0 

If the published reports are accurate. 

12; have asked this in a more general way that covers hrs, but 

Drd the Presrdent ever discuss with ou - I might 

[J]lm ’ oingtoaskitan 

fv. 

rs )Ms. B ewtnskys ’ trans er or finng from the White House with 

ray. Did he ever discuss 

I 9 1 YOU in anv wav? .I 

/lOI -A -No. 

[Ill _Q Did he ever complain without naming her or him a 

[ 12 1 partiilar i;ternNtz,at got transferred? 

[131 

Cl41 Q 

II 9, A 

it he ever discuss Ms. Lewinsky with you at all? 

I --1 

a 

i::;Ms. Lewinsky returning to the White House after she was over 

0% he ever discuss with you the prospect of 

I 18 1 at the Pentaaon? 

r19i A- No. 

1201 Q Did anyone else discuss that with you? 

[21l A No. 

Q 

i::l]youve ’ toldAus a;t.ut this event at Sta 

She never confided inEt;ll other than what 

1241 

1251 - Q No, she did not confide in you? 

Page 102 

A No she did not confide in me. 

MR. WISENBERG: Thats ’ all Ive ’ got for right now. 

~F~%%:WISENBERG: 

il2Y A N6. 

1131 Q 

A 

How about Bob Nash? Do I have that right? 

~::~would talk to him a lot. 

Sure. Hes ’ the director of personnel. Yes. I 

1161 Q That would be a person you would talk to. 

I171 A Yes. 

1181 Q 

A 

Maybe Jodie Torkelson? 

I would always go to Jodie because I wanted more 

i$~money for my staffers and she controkd that. 

I211 Q Patsy Thomasson? 

I221 A No. 

0 

;::;White House - 

Okay. But Bob Nash wwfd be personnel within the 

I251 A Wtiin government. 

Page 103 

Ill Q Okay. All right. But you would not go to hi for 

r2jnonqvemmental. 

I31 A Correct. 

0 

I : i behalf of anybody looking for a’ job? 

Bill Richardson have yar ever gone to hii on 

I61 A No, but Ive ’ called him or hes ’ called ma when hes ’

I 7 1 interviewing people to say what I think, if the 

cstformebeforeorlveknownhowtheywerk ’ ezveworked 

[91 Q Hes ’ called vou? 

t101 A And Ive ’ called him. Sure. 

.--. ,111 BY MR. BINHAK: 

I121 Q .-A life earlier in 

I 131sometimes the President wou ldy 

our answers you said that 

stay al n’ ht and ou would 

[II jleave earlier. You would work all n il ‘ Mat %eMiiHouse. 

I 1s I Is t&re an 

r16lall nght b4I 

particular reason why t e President would stay 

A 

you wouldnY be there? 

i :l; he would often just stay do his paperwork And there were 

I meant that more hguratively than literally but 

[ 191 no mom meetings. there was not 

t2ojof us to stay. 

necessarily a reason for any 

I mean, I would try to stay unbl he left but 

(21 sometimes I couldnt ’ do it. you know. 

_ 1221 Q Let me ask you to think about the study for a 

t23jminute. You said that ouve ’ been in tlw study on occasion 

124 ] With the President, iS t J at COrfed? 

1251 -A Mm-hmm. 

_~__. - ---. 

olcstarr Page 98 to Page 103 

- 
3715 

BSA George Stephanopoulos. 2l3198 

~___~______ 

Page 104 

[II Q Did yew hap en to notice whether the President kept 

lrlgifts in a bag under bus stu&desk? 

A Oh rm sure e did. He would recycle a lot. 

i: 1 know because hegets ’ gazillions of gihs. so he just spreads 

You 

! 5 1 it around. 

[61 Q So ara you saying that youre ’ sure he did because 

[ 7 1 you just think he drcr or - 

[El A No, 1 saw - you know,, its ’ a cluttered oflice. 

[ 9 i You sea - theres ’ g&f clubs on one srde books on another, 

[ 10 Ia little TV. Theres ’ mnkets all around. Yes. So - 

ii,, Q Did vou ever notice a baa in particular under his 

.--a I _ . 

[lrldesk? 

Cl31 A 

Q 

I robably did, but I cant ’ picture it now. 

fhe other ni 

i :: i I think it was Ted Koooel w a 

ht you were speaking on the-news and 

o turned to vou and he said if 

i ;iithe President is watching ou. what advice do ou have to him 

I 17 triqht now and you sad to f ed Koppel this wou h be my advice 

i 18 jt6the President, Im ’ para hrasing iight now - 

1191 A It was to $ eter Jenninas. I think. ,--, 

0 Okay. Either way. mai shows you my television 

~:~~literacy. I apologize. The words ou used, I thank, as 

t22ldosa as I can remember were, My r. President, 

I 7 3 1 out. Is there anv mason YOU chose that formu %bon “! your of story 

itiiwords? ’ - 

I251 A Its ’ live television. I mean, you choose whatever 

Page 105 

[ 1 jwords. You dont ’ choose words. the coma into 

tz]Basically, what I said. what I satd las I night, wha Fur I say Itead. 

(31every night, I think that he has to tell everybody what 

[ 4 I happened. 

[51 0 Is there any particular reason you didnt ’ say to 

161 him, at that point your advce wasnt ’ tell the truth? 

[71 A I think he should tell the truth. There was no 

18 j reason. 

191 Q It was iust the choice of words. 

rioi 

I111 

ll2l 

A Yes. * 

Cl 

A 

Thats ’ really what Im ’ aettin? at. 

Riaht I think he shou tell he truth as auickk 

[;;jas possible. - 

. I 

I141 MR. BINHAK: I have no further questions. 

BY MR. BARGER: 

Page 108 

No reason to believe its ’ not a record of something 

t 

- 

Page 104 to Page 109 

Page 107 

;;I ttyat actuap happened? 

: sldtdnt ’ happen. 

robabty did happen. I have no reason to think it 

Q Okay. Ive ’ asked you a couple of things weve ’

i:jasked you a few questions about would this be unusualbasad ’

[ 6 1 on what you knew at the White House and based on the position 

(7jof Ms. Lewinsky. Im ’ going to ask you a hypothetcal. so 

[ 8 1 obviously by definihon Im ’ askrng yo,u to assume certain 

rslfacts. And were ’ not at all necessant 

[ 10 1 have all been established or that we z 

stating that these 

: 11 junderstand? 

now these. Do you 

[I21 A Sure. 

Q But assume somabod 

I::iwe have described it. assume severa r 

in Ms. Lewinskys ’ osihon as 

rneehngs alone in t \ e 

~15jstudy with the Presaent. several meetings alone in the Oval 

[~s]Offica wrth the President, assume Vernon Jordan taking her to 

[ 17 1 and intmducin 

tlsland talking to %a 

her to a lawyer for the Paula Jones lawsuit 

r about what her testimony woutd ba or what 

1x9 1 her affidavit wouM be, assume atl these peer 

t201mentionad. Bill Richardson, Vernon Jordan, 

le weve ’

Ltty Cunie Bob 

121jNash. John Pddesta, helping her to find employment and assume 

122 ] rough 

t23jWest !& 

20 to 30 visits to the White House, allowed in to the 

rng, lets ’ say 20 visits to tha White House. allowed 

t24 taccess into the West Wrng. after having been transferred for 

[251bein*a dutch. based on your knowledge, what y0.u know at the 

tl+/hiie HOI.?, isygr a highly unusual situation? 

Page 108 

I21 

I31 MR. WlSENBERG: 

I41 

I&Z&ENBERG: 

Pardon me just a moment. 

!:I I think with one exception Im ’ dpne. 

Mr. Barger has a few questions. 

i7i 

~~~outside for just a few moments and 

oing to ask you to step 

en were ’ going to have 

r~olyou back in for what I hope will be a final series of 

1141 THE FOREPERSON: 

t151 MR. WlSENBERG: 

[ 16 1 the questionm 

All right. Im ’ going to turn over 

MR.?3ARGER 

for a whtle to Mr. Bar$er. .’ 

-A while suggests that well ’ be here 

:::{a long time, but thats ‘ noi fair because it wtll be vary 

tlsjbrief. 

I201 THE WITNESS: okay. 

1211 BY MR BARGER 

Q 

;::;a concern about notes that yw mai have taken at the 

Mr. Stephanopoolos the grand jumrs had ec&saed 

t24 twinning of the qua&lni 

t2stjumrs have sorna concern ?! 

somabmeago,andthegrand 

at patips you were faking notes 

0 Page 109 

tzlat their request. we would like to ask you lf you 

t I I about the posstbta rata and sex breakdown of tba u;$~nd, ‘

t lade 

t3tabout that and, if so, why? 

I41 A I did. just for my 

i:;thqse notes and what ou 

Q Canyouelaborateforw memor; atifanypurpqse wtqok 

lan to do with that information 

BY MR. WtgENgERG: 

d 

Has the White House or anyone on their behalf made 

IZ!a request that yw preserve such information? 

1141 tR EhFRb not. 

I::ithats ’ all the uestions I iave. 

Let ma just take a second. I think 

I171 T& WITNESS: Maybe I should ehborate I am 

tle@ting a book on my experiences. For better, forw&, 

tlsltttis has become part of that. 

BY MR. WlSENBERG: 

I think its ’ fair to say on behalf of the grand 

ree of cOncem about their 

0IcstalT 
3716 

BSA George Stephanopoulos, 213198 

~~- XkmxllV 

Page 110 

f : ; jury? 

12: A Oh, no. 

Q Has anybody suggested anything to you that. as you 

i:ithink about It in any way shape or form is meant to 

[ 5; frighten. hinder or obstruct this grand jub? 

16: - A Absolute1 not. _ _ 

171 Q Did you dy o a racial breakdown of the grand jury? 

19: A Race and ender. 

Q Okay. 01 c? you make any notes about where 

~~~~parhcular zcesNor.genders might be seated? 

(111 

Q Did you take any notes about any activities that 

i::ithe grand jurors, particular grand jurors might ba engaged 

~l4]k-r? 

A No. 

0 We might very well ask for ft. There is some - 

I::!. uestion about whether or not we would have the power to take 

tzz 1 4 from you today, so what were ’ instructing you to do is 

tzslpn++setve the integrity of it by not destro 

[24 IdoIng anything to change the way tt ioo 1: 

tng It and not 

tzslunderstand? 

ngM now. Do you 

Page 111 

[II A Mm-hmm. 

VI Q 

A 

Is that a yes? 

Yes. ShouM I just ive it - kt me just make 

r : 1 sure - I wrote down the names of he lawyers, Monica 

[s 1 Lewinsky. the number, target and sub 

it;g A”e” E 

- I did write one slee ng a n the fast two weeks 

~ ?$ct,wi&ss,showrne 

Thats ’ the whole no es. So I guess Bat - that 

~8 jwould maybe a es to your three questions. 

I91 Q About what the jurors were doing? 

t101 A Yes. 

Q Okay. All right. But you do understand our 

i :: idirective for you to preserve the documentary mrity of 

t13lthose notes. 

I141 A Sure. Mm-hmm. 

(151 Q Its ’ got to be a yes or a no. 

1161 A Yes. Yes. 

0 Oka . Can you tell us whether or not looking at 

I:iiER-21 theres ’ a da r e on there 15 January 1996. Can 

[ 19 ) tell us based on your memory whether or not that wes 

ou 

J- 

[2o]one of the bud et crises? 

unng 

ehe tale end of one of them. 

Im ’ going. to ask you to st.ep 

ain and we mll &you back In. 

w~%%%lect that we have 

Page 112 

[l]a quorum. 

121 Is that correct? 

131 THE FOREPERSON: That is cone& 

I::reentered. 

MR. WlSENBERG: And that Mr. Staphanopoulos has 

161 BY MR. WlSENBERG: 

Q Youre ’ the same Mr. Stephanopoubs who has been 

fiiwith us all afternoon. is that correct? 

[91 A Yes. 

Q And I want the record to reRect that ou mentioned 

[ :i;to me out in the hallway that you had given your no r es to 

( 12 1 your lawye; for;;:, to preserve. 

1131 

Q Andthat was the only substantive thin9 that we 

~::~discussedf tky$iway, is that correct? 

I161 

Q Is there anything relevant to our inquiry as I 

[~~[~h;s~:~o;,at the beginning when I went over our 

an hmgorelevant o our inquiry that you havent ’

[211 . A Not that I knowpf. 

I221 Q .Oftenyple wtll come to the grand jury and even 

i 23 j if theyre ’ questroned or qurte some bme like you have been 

t 24 tthey will leave and theyll ’ be driving in their car and 

[Z 5 1 theyll ’ remember something and theyll ’ say, %osh. I cant ’

OlCStarr 

Page 113 

: 11 believe I forg.ot.” And ti might very wetI be something 

: 2 1 thats ’ tnconsrstent wrth what you Sa!d In the grand .ury. 

: 31that happens, I wouM appreciate d $ through your 

If 

lawyer, 

c 4 1 of course, you would get tn touch with me or one of my 

: 5 1 colleagues. 

161 A Oka 

171 MR. WtSENBERG: If there is nothing further, we 

Cl61 

..*t. 

1171 

1181 

I191 

[201 

I211 

1221 

I231 

(241 

1251 - 

I - 

Page 110 to Page 113 
3717 

Mona Sutphen, 327198 

Deposition 

Page 2 to Page ,_ 

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 
3718 

Mona Sutphen, 5/27/98 xw.xllrl) 

[I! 

Page 3 

PROCEEDINGS 

This deposition is being held at 2101 L Street 

t76iN.W. Washington D. C. The name of the witness is Ms. Mona 

[alSutphen. This deposition of Ms. Sutphen is being taken by 

[sIthe Office.of the Independent Counsel In Re: Grand Jury 

[lot mvestrgarron. 

II 11 At this time. the attornevs will identifv 

i ;; i themselves lease. 

-. 

I131 t&f BIENERT: Thomas H. Bienert. Jr. 

1141 MR. LERNER: Crai S. Lemer. 

VIDEOGRAPHER: % this time the court reporter will 

~:~jidentify herself and swear in the witness, please. 

COURT REPORTER: 

KIIWHEREUPON 

My name is Elizabeth Eastman. i 

! 

1191. MO@ SUTPHW ._ _- _ ._ 

, 

Cl81 Q Do you have any questions about what perjury is? 

[I91 A No. 

0 

[201 having been called for examination by the Ottroe of tne ! :i ; and if someone is prosecuted and convioted of 

And let me also advise you that pejury is a aim, 

t211 Independent Counsel and having been first duly sworn by the rzztcan face up to five years in jail and a fine of up po ” 

r~ury they 

t22 1 notary, was examined and testiied as follows: 

EXAMINATION BY OFFICE OF THE INDEPENDENT CO 

[23]$2~,~0. Do ou understand that? 

1231 NSELr24 I A u;,s. 

t241 BY MR. BIENERT: 

.--, 

Q Maam. ’ once again, my name is Thomas Bienert An 

1251 Q Any questions? 

t251 

Page 5 

I!‘ A 

Q 

Okay. 

!1 Now, In, terms of a grand jury appearance yru have 

I ;.a couple of Important ri 

? 

hts. and then 

: 4 extremely Important ob lgatlon SO, le Y 

ou have a very 

I 5 1 nahts first 

me tell you your 

e answer co& 

[!i ‘ Q And what that means is that a uestion that you 

[ l-iibelieve that the answer to might somehow imp 9. rcate you in a 

i 14 ;cnmmal a% D;zz.u understand that? 

I151 

0 Do you have any questions about your Fiih 

I :7” 1 Arnendmeit rig;;: 

I181 

Q 

I:ijcounsel. and 

Secondly, you have a right to be represented by 

ou can consult with your counsel about the 

rzllappearance. u, ou can even meet with your counsel during your 

r221grand jury testimony. The only limitation on that is the 

[23]attorney cannot actually be in the room with us but he can 

(24 lbe in-the r?rn ~~;t door. Do you understand that? 

I251 

Page 6 

(11 Q And you are represented by counsel today, correct? 

I21 A Yes. 

(31 2 What is his name? 

[41 Jushn Srmon. 

Q And Mr. Simon in fact is next door and we are in 

Iz i his offices of Dickstein Shapiro, correct? 

A Correct: 

ou have an extremely important 

tl~along with Craig Lemer, we are Associate Independent 

t2$ounsel, which in essence means we are attorneys working for 

[ 3 1 the Independent Counsels ’ Office. 

I41 A Okay. 

Q Let me give you a couple of admonitions and the 

iziground rules for how we are 

! 

t7lwe are doing this as though 9 

oing to proceed. First of all. 

A Okay. 

I were before the grand jury. I 

I81 1 

Cl As an accommodation to you and your counsel, weve! ’

riilagreed that we would do it in this setting and then show the I 

[~l~vldea to the rand jury, as o posed to making you physically 

r12Jcom down & ere. But all ot t 

I 131 in front of the qrand jury. 

er rules apply, as if you were 

Okay? 

i14j A -Okay . _ 

Q What that means is a couple of thin s. First of 

~:~~all. just from a practical standpoint, let me point ou P to 

[ 17Jyou that the court reporter is gojng to make a transcript of 

rlsreverything that IS said. So, rts important that we do a 

rlgjcouple ofthings. I 

Number one, that we try to answer with words 

Izi;instead of gestures, because she cant ‘ take down gestures. 

[22tAnd, number two, that we try not to talk over each other, 

c23lbecause its ’ hard for her to 

(24 Ispeaking at once, and it WII .P 

et it down with two people / 

make the vrdeotape, the audio 

[25Jpolfion. a little more difficult, too. Okay? 

Page 7 

[II A No. 

t21 Q 

A 

All right. Where do you work? 

\:!the Department of State in Washrnaton. DC. 

Im ’ a career Foreign Service Officer employed by 

i5j 

161 

’ AQ And who s 

I work fort R” 

cificall~do, you work for maam? ’

e U.S. Mission to the U.N. and Im ’

J7 Jass@ned to Ambassador Bill Richardson. 

ISI Q 

rglRrchardson? 

And how long have you worked for Ambassador Bill 

rioj A 

Q 

A year and a month. 

IllI Drd you sit in on an interview with Monica Lewinsky 

r12ron October31st of 1997? .--. 

I131 A Yes, I did. 

Q Prior to that interview when was the first time 

(16JMs. lewinsky? 

I:!,lthat ou would have heard anything or learned anything about 

1171 A The evening before. 

I181 Q So, that would have been the 3Oth? 

Cl91 A The 30th. right. 

[201 Q All t-i ht. - 

MR. LERfiER: 

i::;the calendar ust ‘ for future use. 

Perhaps we should just again introduce 

[23J Md. BIENERT: Okav. Whv dont ’ we do that. 

[24i 

J251 

(Grand Jury Exhibit MS-1 was 

marked for identification.) 

OIC-Starr to Page 7 
3719 

BSA 

Page 8 

Mona Sutphen, 5127198 XMAX(U2) 

Page 11 

BY MR. BIENERT 

Cl What we are docng. just to make things a little 

: easier. IS to use a calendar 

A Okay. 

Q Then you can keep track of what days were what 

A 

,. Q Eoghtrhe ’ 31 st was a Friday, correct? 

.z A Right. 

Q So, you believe the first time you would have had 

: 1; any involvement in anythin 

: _ have been the 30th. corre c? 

relating to Ms. Lewinsky would 

? 

_- A Yes, correct. 

Q 

ii ‘ the interview? 

Now, did you ever see a copy of her resume prior to 

.--. A Yes. 

1;. ‘

_*- Q 

A 

When would you have seen the resume? 

[:-: On the afternoon of the 30th. 

113: Q 

ilj:Ms. Su 

Okay. And if we could go ahead and place before 

!2::2A nun%er on it. 

hen what we will call -this one actually has an IW- 

:::: A Okay. 

:,-. 

.--, Q Tell us. maam. ’ if you recognize what that is? 

77. ‘

,--, A Yes. 

,:.:. j 0 Is that the resume that you saw of Ms. Lewinsky? 

;75: A Yes, it is. 

Page 9 

. . Q Now, this resume, if 

:s jshows that it was faxed on October 

ou look at the to of it, it 

3 lst, which woul s have 

: 3 : been approximately 10 days before the Interview, correct? 

[.I: A Correct. 

15: Q Is it accurate, maam ’ though that you would not 

: E : have seen it when it was faxed over? 

.-. 

, A Correct. I didnt ’ see it. 

;r. 

.-_ Q And you didnt ’ even see it until the 3Oth? 

:4: A Correct. 

I_’ 

--_ Q So, is it also accurate, maam, ’ that you would have 

1: : had no involvement prior to the 36th rn any discussions with 

:z: anyone about whether to schedule her for an interview, when 

: 3: to schedule her for an interview, et cetera? 

1:: A Correct. Yeah, I had no knowledge of it 

! 1 s : beforehand. 

I::; 

Q And therefore I assume it is also accurate that 

ou would not haveparticipated ’ in any telephone calls with 

[I 8 I I4 

I191 

s. Lewiniky p;~;~~Qctober 36th? 

(201 Q What is our phone extension? 

(211 A KS 

Q 

-Y 

Where is our office ph sically located in relation 

iz:jto for example Ms. Wat 

[ 24 1 RikhiWdSOdS d&k? 

I!’ I& desk a JAmbassador 

I251 A The office is shaped kind of in an L. Ambassador 

Page 10 

t 11 Richardsons ’ office is at the end of the L. Ms. Watkins is 

~21 I woukl say, the closest office to Ambassador Richardsons ’

[ 3 1 office, but its ’ not directly adjacent to that. And then Im ’

[ 4 1 basically two offices down from &belle. Theres ’ one office 

; s 1 between us. but it% kind of an open area. 

I 6 I and out. 

People walk in 

[I ‘

181 AQ 

Cl 

%$are not dosed. 

What I am going to do is have placed before you 

ri?ithree exhibits that are various phone records. So, these 

(111 will be MS-Z, MS-3 and MS4 

1121 (Grand Jury Exhibits MS-2, MS-3 

1131 and MS-4 were marked for 

114 I identification.) 

II 

I:: 

BY MR. BIENERT: 

I ‘ Q I would suggest to you the easiest thing to 

117 I because 

1 c&onolq 

unfortunately I bounce back and forth 

gicalty would just be to lay the three out in front 

t :“, 1 or you as I have done. 

i2;: A Okay. 

121: Q And then we will trv to ao in order. 

do, 

.~~, 

[22?. 

[Z?j 

A Okay. 

a ” 

Q Beginning with the 36th. 

124; 

125: 

A Okay. - 

0 Okay, maam. ’ Now, Ill ’ just represent to you that 

Page 8 to Page 13 

: I! Exhibits 2 and 3 are records that the Independent Counsels ’

12 I Office obtained from your office -- 

!3’ 

!JI 

$ Okay 

__ In response to subpoenas for any phone records 

: 5 J relating tozlls rnvolvrng MS Lewrnsky. 

[hi 

!?I Q ?Ik,“,Yof the records I believe its ’ Exhibit 2 

i B 1 indicates calls from your office or people in your office --’ 

!31 

!I01 

; Suite. nght. 

! I I 1703 number. 

-- to Ms. Lewinskys ’ Pentagon office number, the 

!:?; A Okay 

Q Exhrbrt 3 represents or identifies calls 

i :: ~offices to Ms. Lewinskys ’ home number, whrch is the 

tlslnumber. 

[I61 A Right, oka 

1171 Q Then, fina Y ly. Exhibit 4 indicates calls by Ms. 

tls]Lewinsky from different numbers or different phones to your 

tlsloffices at the - 

I201 A At the Mission. 

1211 

I221 AQ uo-t\t. 

I231 Q So, kind of walking our way through this, and what 

[ 24 1 Ive ’ done is ust ‘ sort of drawn a line for myself beginnin 

t251wtth the 30t c, so that we dont ’ go over the calls that pre 8 ate 

Page 12 

1 I1 that, and Im ’ goin 

? 

to make a line on your copies as well, so 

[zlthat we dont ’ con use ourselves even more. 

t31 A Right. 

[41 Q You might want to do the same on that document. 

151 A Right. 

Q Now startin 

17”;l believe, indicated on the 3 & 

with the 30th there are four calls, 

h. The first one indicated is 

[B 1 going to be at 1 :Oi in the afternoon. 

I91 A Okay. 

[IO1 Q A call that goes from extension w 

[ill A Ri ht. 

[l?l Q -90 Ms. Lewinsk s ‘ Pentagon number and that call 

[ 13rwas l-minute, l&seconds. It .r IS hen followed by a call at 

[141- let me make sure that Im ’ looking at these right. Am I 

tlsllooking at the right one here, 10 and 11 - oh, well ’ come 

tlsjback over here. No, okay. 

[I71 A Up here? 

[I81 Q Lets ’ go over to this side. 

[I91 

% %&en have two more calls: one at 16.45 or 4:45, 

I:y!frorn extension 4462 for 42 seconds to Ms. Lewinskys ’ ho&e 

122 1 number a her call at 5:28 from Ms. Watkins’ ass’ t-red 

r23inumber *a to Ms. Lewinskys ’ home number; and w en finally 

t24)we have a call, ffwe come over to this side, which is from 

t251Ms. Lewinskys ’ phone at the Pentagon to extension w 

Page 13 

111 

r21 8 %&J see that one? 

131 A Yes. 

Q Now, first of al 

i:l]either to o~fromy~~nsion r19 

II four of these calls then are 

Do you see that? 

161 

[71 Q Is that an extension that you would use? 

1st A Sometimes, yes. 

Q 

t!zithose calls? 

Do you believe that you participated in any of 

[Ill A 

Q 

No, I do not. 

Do 

I::jLewinsky on the 3 4 

ou believe that you made any calls to Ms. 

h? 

t141 A 

Q 

I did make a call to Ms. Lewinsky on the 36th. 

Oka 

I:zjhave made that cal x 

And from what phone do you believe you would 

t171 A I dont ’ remember. I think it was from the - once 

[lslwe got to Washington. 

[I91 0 So, in other words - 

PO1 A 

[211 Q 

In the evening. 

(221 

1231 R” 

All right. So, you believe -which would explain 

rhaps why there is no record on the stuff that we got from 

eW York -. 

1241 

[251 Aa cofrect. - related to that call. 

_. 

OIC-Starr 
3720 

BSA Mona Sutphen. 5127198 XMAX(Y3) 

Page 14 

I.. 

. A 

C CWohr~~ould have been the conversahon tnat you had 

i !jwith Ms. Ly nsky? 

11’ I calied her to arranoe to meet the next !he next 

: i:morning. Isabelle had moved the sppointment around a couple 

i,jof times, wP.ch is probably wh there is so man calls back 

.- and forth. A-d I wanted to ma L e sure, confirm t K at she was 

is -still plannin,- on coming. what time it was the appointme-: 

:was ‘‘ set for a-d then arrange to meet her in the lobby to 

i i:: take her up ?o the Ambassadors ’ suite. 

i1:: Q 

iiT: A 

e;z. did you make such arrangements7 

il3! 

: ii ; correct? 

Q Now, the next dav was the actual interview. 

ii51 A Cot-red. 

[I61 Q And who was present at the interview? 

A I was there Ambassador Richardson obviously, 

I:iiMonica Lewlnsky, and ourchief ’ of staff, Rebecca Cooper. was 

[lglthere as well. 

Q What was your understanding, up until the - lets ’

i:yltake the timeframe from when you first learned she was 

r~linterviewina LID until the time you literally walked in and 

isjjmet her. - 

[241 A Uh-huh. 

[251 Q What was your understanding of what she was 

Page 15 

[ 11 interviewin 

B 

for? 

A job in -well I knew of two openin s. There 

i:!was one that I knew our chief of staff was interest Jin 

[.I lwhich was a public affairs-related position in New York: 

rslThere was also an opening that was coming open In our 

i~jprotocoloffice - 

ITI Q And where was that the protocol - 

181 A Both in New York. 60th in New York. 

Q What was your understanding of - first of all, how 

rji!did you know that Ms. Lewinsky was interviewing for a 

[~~iposltion in New York as opposed, for example, to a position 

[1211n Washin ton? 

1131 %, Oh, we didnt ’ know that until we talked to her. 

Ll41 Q Okay. 

[I51 A In the interview. 

Q Did 

i :7”; Richardson about rx 

ou have any discussions with Ambassador 

s. 

A 

Lewinsky prior to the interview? 

No. I asked him whether or not he wanted to - in 

i:i;the evening on the 30th. as we were headed down to 

[zo]Washington. I asked him whether or not he wanted to k@ at 

[nilher resume. And he said no, just make sure you have tt for 

(2211~ in the morning beforehand. So, beyond that, no. And In 

(23)the momi 

3 

I put It in his suite. 

So during the interview she indicated to you and 

i::ipresumably Ambassador ’ Richardson and, who else, Ms. Cooper? 

Page 17 

1: Rlchardson has a 

Department and I 

Q Now. lets ’ go ahead and place In front of you a 

: - couple of exhibits. 

(Grand Jury Exhibits MS-5 and 

.? MS-6 were marked for 

il? Identification.) 

:::. BY MR. BIENERT: 

;::‘ 

: 3 7. is. I will 

Q Maam, ’ if you just look at Exhibit 5 first, which 

re 

11; : at the top R 

resent to you, a M 

ovember 2nd, 199 P 

y of a letter that is dated 

, that was taken off of Ms. 

: : 5: Lewinskys ’ corn uter. 

[16] A C?kay. 

Q Retneved from her computer. And you will note, it 

:: z istarts off with “Dear Bet&“. 

i19! A Yes. . 

[?rjj Q What I want to point your attention to, and I will 

(11; go ahead and bracket it - and you are certain1 welcome to 

12~ 1 read as much of the letter as you would like - 6 ut I want to 

~23: point our attention to the 

Ex K- P 

aragraph that I have bracketed 

124 ; on iblt 5, and ask you o read that to yourself. 

[?51 A Okay. 

Page 18 

;i; 

ltness reviewed the document. 

F Now first of all, if you look a 

[ 51 we take th; dat;io;tlovember 2nd - 

1 the calendar, if 

[4’ 

151 

i6j 

Q -?hats ’ a Sunday 

A Sunday, ri ht. _’ 

Q And thats ’ 9 

Ii ; interview with Ms. Lewinsky, correct. 

he Sunday immediately after the 

i9! A Correct. 

Q Now, if you look at that first line of the 

I fp: paragraph; havGhb;;c$eted - 

!12j 

Q -- 1 ‘ became a bit nervous this weekend when I 

I :: j realized that Ambassador Richardson said his staff wouM be 

[ 1 sj in touch with me this week”, and then it goes on to talk 

116 1 about what should I say, et cetera. 

I guess the question I have is, doyou recall at 

1 :ii the interview on the 31st was there any indication to Ms. 

[I 91 Lewinsky that you recall ihat someone would be in touch with 

~201 her the next week? 

A I remember when I - not at the interview its&, 

I::; but when I walked her dew? afler the interview, down to the 

;;:;kig and at that 

w&h her. I d%?tAi%? % s&zgy&?d “‘ be In 

~zs~particular week. But I said in the itext w&k or so. 

[II 

121 

Page 16 

A0 Uh-huh. - who was Dresent. that she wanted to work in New 

i;;York? 

A Yes. I was - I didnY - I was kind of in and out 

i:iof the room. I was doin other, other thin s looking in the 

[6]sUite. But it became - P dont ’ know how i?’ became deal to 

r,,rne that she was interested in a job in New York, but I dtd 

isjknow that.QSo. 

[91 Now, followin the interview did you 

[lOI MR. LERNER: (?an-I just stop for a moment? 

1111 BY MR. LERNER: 

1121 Q October 30th was the first time you heard Monica 

[ 13 1 Lewinskys ’ name? 

[141 A Yes. 

1151 Q Is that correct? 

Page 19 

Q Okay. So, you believe that at a minimum you would 

I: i have said ~rnett;~~~g those lines, IS - 

[lOI 

rlllane-mailF&f bf all. I will represent to you that this is 

L--1 

!I21 

Aa Okay. - that was obtained through the investigation, 

1:: ;sent, if you will look at the top, from Monica Lewinsky - 

l,CIl A Rioht. .--. 

1161 r171 

2 correci 

How did that come UD? 

x 

..-.. -.- _..__ _-..._ _~ 

I normally go over the schedule for the next day. 

I::{And if there are things on it that I dont ’ know what it is, 

rzolthen Ill ’ try and figure out who put something on the 

[2llschedule and whether or not hes ’ going to need anythin.g in 

(22) reparation for it. So, I asked Isabelle, you know, who IS 

~231 L ontca Lewinsky and why are we meebng with her, and what do 

(24 ) I need for that meeti 

[251 Q And \2;l& did she say? 

L--. 

[161 - fb a friend of hers named C.A. Davis in Japan. 

1171 2 Oh, okay. R$ht. 

Q And tha the ate and time on the e-mail from Ms. 

i :“91 Lewinsky shows November 5th at 2:16 a.m. So, it wouM have 

[20!been - 

I211 ; At.2 oclock ’ in the morning? 

- In the wee hours of the momin 

I 

. So, at least 

i::lbased on that date I think that rt would represen the 

(24 Idocument indicatei it was written, say, the night of the 4th 

r2s!and into the morning of the 5th. 

OlCStari Page 14 to Page 19 
3721 

BSA 

Page 20 

Mona Sutphen, 5127199 

:. 

$ %sri$! ~I!$ ‘ if you could just read that 

:i -paragraph that I have? 

A Okay. 

r: - ltness 

’ 5 r 

reviewed the document.) 

Okay, have you read it? 

,- A YPC 

i? Q ‘ 6% of all if we look at that, and looking at 

1 ;-the timeframe at least indicated ’ on the e-mall - 

!:3 

ii:: 

(12: 

8 R&rrt-$~t;~ft$e 4th. the morning - 

[13! 

rl4,before- -- 

of the Sth, IS it accurate that the Friday 

iisi A0 Right. -was the date that you and Ms. Cooper and 

::76jAmbassador Richardson interviewed Ms. Lewinsky? 

[Is! A Correct. 

Q 

I:: i great guy and I met two women who work or hrm also very 

Okay. It also goes on to say “Richardson is a 

rz~;cool.” And it is accurate that the 

rrz~interview were voursetf. another P emale. and the Ambassador. 

eopte who did the 

izjjisthatright? = 

I241 A Correct, right. 

[ZSI Q Then it says, “Yesterday, Richardson called me at 

Page 21 

[ 11 work and told me they were going to offer me a position. 

[z IThey didnt ’ know what yet and they wanted to talk with me 

[ 3 1 further.” 

I41 Keep that in mind, and then Ill ’ dire& your 

[ 5 1 attention to. I believe its ’ going to be Exhibit 2. and 111 ’

[ 6 1 put a little asterisk next to the call that Im ’ directin 

t-rlyour attention to. Thats ’ another phone record ob 8. alned from 

[8lyouroffice- 

!91 

1101 Aa Rifht. - hat Indicates that on November 3raIsI : 02) 

r:lla.m., there was a 2-minute, 54-second call from extension 

[~z+%tJ+ with the name William Richardson assigned to it, to Ms. 

tl3jLewtnskys ’ Pentagon number. Do you see that? 

Cl41 A Correct. I see that. 

[ISI Q Is it accurate that a job offer was extended to Ms. 

[ 16 J Lewinsky on November 3rd? 

A 

~:~~Srd. But there was a iob offer extended to her within the 

I dont ’ remember exadty whether or not it was the 

tlgjweek after. 

1201 Q Namely, within the week aher ’ her interview? 

[Zll A Yeah. 

[221 Q So, the offer - 

1231 A 

Q 

I thought 1 was a week to 10 days, but. 

IZiconveyed? 

But you were aware there was some sort of offer 

Page 22 

(11 A Yes. 

r21 Q Do you know how the offer was conveyed? 

131 A Yes. 

I41 Q Howwas it? 

A I called her and offered her a position in the 

~~l)office. Told her that we wanted to bring her on to do a 

;;;$~$.$s~pe ’

job that we had discussed in the 

told her that we wanted to set up a time to 

[ 9 1 bring her toQNewO;zrk 

101 

111 A To dy rscuss details. 

121 Q Now. do YOU believe that this is the call that vou 

i 13 jwoukl have made? _ 

[I41 A I believe - is there another one between that time 

[lsjand - 

Q There are - just so 

I:76jcomptete and we can kind of skim a 

oull ’ know to kind of make it 

own - there are calls, so 

[ 18 1 that you know kind of the sum total of the calls. We have 

[1s]that call on November 3rd. 

t201 A Right. 

I211 Q Then, if you look over here, there are a couple of 

tzr~calls on the 14th - Im ’ sorry, its ’ one call. It just shows 

t23]hvice. 

I241 A Okay. 

I251 Q Theres ‘ a call on the 14th - 

[II 

!?! 

Page 23 

A R.aht. 

Q - To extension a 

:3! 

!41 

A Oqay 

Q Theres ’ a:so a call on the 24th -- 

A R,Sht. 

- ihat goes to your extension,- 

AQ 04av. 

jYi Q Andthere ’ was a call I missed in between tn.s 

9 IThere is a?ll on the ,l Seth - 

;:01 1 %h. right 

:111 Q - to your extension as well. 

[!?j A Yeah Those are all too late. So, yes, that 

:13jprobably was the call. 

1141 Q Meanmg the November 3rd call? 

1151 A The November 3rd call. 

Q 

1::; number? How does that work? 

Now how would you wind up calling from the_ 

A Its ’ on my telephone. We all in our suite, ali 

::89jhave all of the extensions of everybody on them. 

[ZOI Q Right. 

I211 A And I don? remember exact1 whether I calted her 

tzz]- I also sometimes make calls - as you wa Y k out of 

123lAmbassador Rrchardsons ’ office, there are two desks right out 

[24 Ifront. And if Im ’ pretty busy in a day and I want to get 

t25]somethlng done, I SOmetImeS Wilt jUSt sit down there and pick 

t1,up the phone and do it while Im ’ thinking about it, rather 

Page 24 

12 1 than gotn back,to my office where I mrght forget Im ’

t3lsuppose rig to do d. So, one of those two things. 

Q If we 

i:iwas on Fridav. the 3 ? 

o back to the calendar again, the interviAv 

st. 

isi 

I71 

181 

A -.Yeah. the 31st, ri ht. 

Q The 3rd was the il rst working day back. 

A Correct. . 

Q 

r:Ijthe 1st and 2nd? 

And is it accurate that you probably didnt ’ work on 

[Ill A Probably did work on the 1st and 2nd. 

I121 Q 

I 131~111 to Ms. 

When, in relation - Im ’ assuming if you made a 

Lewinsky about the job, ou would not have done 

[I 4 1 that witho; contg 

[I51 3 

.wrth the Am z assador? 

I161 Q 

ii7j 

So. YOU did it at his direction? 

A Yes_~correrX 

Q 

I:t;you would have spoken to him? 

Do you know when, in relation to the call you made, 

A 

I::; it probably woutd have been the morning of the 3rd. 

Like. I mean, Im ’ with him almost constant&. But 

0 

~::~call immedtte 

And do you believe that you woukt have made the 

after speaking wtth him about it? 

C.241 

1251 Q 

%&ably. Yes. . 

AA right. Do you know whether he spoke on the 

Page 25 

Lets ’ start with the one with Ms. Lewinsky when you 

A Okay. I caked her. I told her that we wanted to 

189iextend an offer to her to come work at the Mission in New 

/::ibrin 

She said that - when I told her that we wanted to 

% 

her up to New York, she said that she thought that she 

t24lwou be traveling. She wasnt ’ a hundred percent sure when 

tzslshe would be able to come up to New York, and I said that was 

Page 20 to Page 25 OlCStan 
3722 

BSA Mona Sutphen, 5127198 XMAXZ.5) 

Page 26 

: fine. and that we would touch base r another cotmle of 

: weeks. 

0 All right. First of all. ;e:s ‘ back up. Tell us 

: about the conversation that vou had stth the Ambassador that 

: led to your -- 

$ Which led to the call’ 

__ call to her? I A He called me into the office and said. you know, 

:-Ive ’ decided to hire Monica Lewinsky what do you think. And 

._ -I said, oh, you know, thats ’ fine. I sad, are you sure: and 

1: : he said, yeah, yeah, Im ’ sure, why. And I said, no, no, you 

;I : know, theres ’ no Issue; are you sure though you dont ’ want to 

: 3 : talk to an body else, you dont ’ want to interview anybody 

: 4 :else. An a he said, no, no, I think its ’ fine;, why dont ’ you 

:G: ? o bnng her up to New York and actualty. yqu know, talk to 

o ahead and give her an offer. And I said, I think we ought 

17 ; her,.show her where shed ’ actually be working and, you know, 

~?;gel Into more detail. And he said, yeah, tha,ts ’ a good idea, 

:91wh 

\ 

dont ’ you call her and try to set something up; bring her 

20: up ere and well ’ bring up Rebecca for the day, too. ^. . Q 

i32jother ’ people? 

Why dtd you ask him if he wanted to interview any 

i-13; 

1:: jvery 

A 

[ 2 5 1 hired 9 

uick. 

Well, at the time I thought that it was 

And in retrospect, even though I was km .*lI 

ou know, 

of 

hat way, like about. in fact, much quicker, after 

Page 27 Page 30 

For that kind qf job? 

that was being kicked around? 

lthink Rebecca Cooper may have talked to some 

11s I,P hat Ambassador Richardson actually interviewed. 

eople or had some people in mind for it, but not anybody 

[I61 Q All right. 

[I1 ’ A 

Q 

At least as far as Im ’ aware, that I was art of. 

Okay. So again at the time it see 

~:~~quick but since then 

rneZa little 

rzolon &era1 occasions. Y 

o&e see; him ad in a similar manner 

(1 lsecretaries who are out front. And its ’ a number that you 

[ 2 1 know, once people get their hands on, we get a lot of calls 

[ 3 1 to that extension. 

[41 Q 

A 

Did you have any - 

So tt would be we have three two secretaries 

~~~full-time there. I&belle answ&s that line. Ill’answer ’ it 

[71if theres ’ nobody around. Our depu ambassador in New York 

(8 1 has a secreta Shell ’ answer it. I$ 

[ 91 the entryway. ryT 

e have somebody out in 

Q 

hey will answer it. So. 

So based on the fact that its ’ a one to 2-minute 

~:~~call at 111 is it accurate ’ that an 

[I: 1 have been the person who picke J 

number of people could 

up the phone? 

(131 A Correct. 

0 Do you have any basis to conclude who she 

1::; ultimately spoke to in that conversation? 

[I61 A I have absolutely no idea. 

[ITI Q Now, the next call that involves - 

r1e1 MR. LERNER: Can I interrupt for a second? 

[191 BY MR. LERNER: 

Q What number did you give out to Ms. Lewins 

[iF;you remember in terms of when she wanted to contact peop 

[221at the United dations? 

tdo 

[231 A Hmm. I know I 

1241 Q That would be 4% 

ave her my number at one point 

297 

[251 A 4029. 

i21j A Yes. 

Q 

i::labout either that conversation or the one with Ms. Lewinskv? 

All right. Anything else stand out in your mind 

iz4i 

1251 

A No. 

Q Okay. 

Page 28 

III BY MR. LERNER: 

Q Did you make dear what the position would be for 

i:iher at the United Nations or was there some sort of openf 4 1 endedness when you e&nded this offer? 

A There was an o n-endedness because it was a new 

izi osition which is somethin I t Ink I should explain. We 

[T l/ad sor6epbod y who left our%&%ngton Dffice. It was a 

[ 8 lpoliiical a potntee slot. And Rebecca Cooper, who is in 

[slearge o our public outreach was 

[ ~~lin New York to serve as an assistant 7

keen to have somebody 

1111 public outreach efforts. 

her, to work on 

Q Now lets ’ look at what weve ’ already highlighted. 

/:: i a couple other calls~ I guess we can 

[z 51 of paper because weve ’ covered all o 3” 

t tid of this piece 

them. 

Page 29 

Now, theres ’ a call I think on this one. There was 

: I a call on November 19th from your extension for 48 seconds :3 

: ? ; MS Lewlnsky. 

4‘ ’ A Riaht. 

;\I Q 

;,!on the 14th - 

Theres ’ a call, actually I guess a few days befc:e 

r-1 A Ri ht. 

2. ‘ Q -9 rom Ms. Lewinsky to _ Lets ’ focus on !?at 

.j i one! which IS the, next in order. 

[ : 2 : participat: In ,‘“z call? 

Do you believe that you 

[!I] 

[:21 (1 First of all, what is your basis for concludina 

I 13 1 that you did not participate in it? 

i;41 . A Because every time I spoke to her I remember 

[ lslir$ating the call. I mean, I didnt ’ always get through 

[ 16lnghl away. but ou know she would call me back. 

Q 2nd ‘ so the’ fact that this is a call from her to 

t :i i this 4404 number at least for a minute - its ’ unclear 

( I 9 1 whether it was a hinute or two, but somewhere in that 

[ 20 1 timeframe - that makes you believe it was not you who she 

12: I spoke with? 

i221 A Correct. 

Q Now if somebody calls this -number, who 

I::]answers the phone? 

L251 A Any number of people, basically any of the 

Page 31 

;:;a 

Q So, when she wanted to reach you, she would call 

A Correct. I would assume so that she would have. 

I:; If she didn\ know - I dont ’ know how she Gould have gotten 

[slit otherwise. 

[61 BY MR. BIENERT: 

Q 

iii to your number is the one on the 19th. 

Now, the next call, and it then also turns it goes 

[91 A kight. 

f101 Q Then we have the one on the 24th. 

Ill1 A Right. 

i $!14th. 

Q So, ou dont ’ know anything about this call on the 

You believe I .r was not you, correct? 

[I41 A Right. 

I151 Q But you dont ’ know what the subject matter was? 

[I61 A Correct. 

;:;;lgth? 

Q All right. What, if anything, was discussed on the 

1191 A I think - 

I201 Q her? 

A 

That would be you callin 

Right. I think thats ’ abou 9 that was about two 

I::;weeks later after our initial conversation.’ So I probably 

[ 2 3 1 ust ‘ was following 

i 

u 

P 

And from the length of the time of 

[24 1 he cal!, we obvious y dtdnt ’ have a conversation. I think 

[z 5 I every time I called her there was - I left a message and she 

OlCStarr Page 26 to Page 31 
6% 

Page 32 

3723 

Mona Sutphen, 5127196 XMAX(b6) 

Page 35 

Q All rtght Whats ’ the signficance of these notes? 

t l i What does that mean? 1 A He basically -- we received thrs, I think 

ii :dont ’ remember, but It was signrficantly af% we had 

ma 

talke 

:5 

i6 

[i 

I? 

~called back. 

1 Q All right. 

1 A 

Q 

So, maybe she called me back. 

And then by example, we see on the 24th. there is 

.-- and, agarn. I have to confess, I havent ’ fi 

; totally what these discrepancies are. 

ured out 

But c 9 early each 

1 number appears twtce. And based on the timing it appears to 

be ‘ the same call. 

(5‘ A Right. 

!I01 Q One is shown as seven minutes! one is four. But, 

[ I I j in any eveit, it giaita several-minute conversahon? 

iI 

113: 0 W?rat do you believe you would have spoken to her 

r I 4 i about on that occasion? 

fsi ‘ A On that occasion, I was calling to follow up to try 

: I 6 1 to set up a time for her to come to New York. 

:171 Q Did she indicate she was interested in that, or was 

.~s]she stonewallin you or what? 

191 ‘ A 8he did. But she also said that she asked me 

zo 1 whether or not she could be honest with me. Isaid ’

21lcourse. And she said, well, you know, would the Am 

es, of 

%b ‘ assador 

221 be upset if I wanted to take a little bit more time to think 

zslabout it. And I said, well, you know, no, I dont ’ think so. 

24 1 not necessarily. And she said, well, because Im ’ looking at 

251 some other options in the private sector; Im ’ not a hundred 

Page 33 

~1: 

[2 1 P 

ercent sure if I want to continue my work in government and 

need a little bit more time to figure that out. And I 

~3 1 said, Im ’ sure that would be okay, and if its ’ not Ill ’ get 

[ 4 1 back to you; but, if not, then Ill ’ call you in another 

r51couple of weeks and we can set somethina UD then. And we 

[ 6 ] agreed to touch base again later. 

_ . 

Q 

ii 1 the Ambassador? 

And did you, in fact, convey that information to 

isj A Yes. 

[lOI Q What was his reaction? 

[II!. A Well, also in that conversation, I had the 

I 12 1 !mpression that she wasnt ’

[13]]ust my impression. But I to 9 d hrm that, that 

oing to take the 

I 

ob. It was 

114 1 wrth her and it was my.im 

had spoken 

I 15 1 she was gorng to take It. E 

ression that I didnt ’ think that 

t 

rls]the 

117 1 oh, g 

at she wanted to get something in 

nvate sector. And he asked me, well, why. And I sard. 

ecause I think shes ’ looking for something in the 

[IE] 

P 

nvate sector. And he said, hmm. And I said, but she asked 

t 19 ] or some more time, you know, is that okay. And he said, 

tzo]yeah. yeah, thats ’ fine. 

Q 

i%ito be on the 5th. 

All right. Then the next call that we see is going 

rzs]a document. 

First of all, let me go back and show you 

i24j A Oka 

t251 Q Tharis going to be MS-7. 

Page 34 

t11 (Grand Jury Exhibit MS-7 was 

(21 marked for identification.) 

I31 BY MR. BIENERT: 

Q Go ahead.and read the typewritten part, but also 

I:;look at the;ote;;;;;e right.. 

[Cl 

171 Q Tei us when you are ready. 

181 (Witness reviewed the document.] 

isi A Okay. 

Q This is, in essence a thank-you letter dated 

i:yiNovember 3rd from Ms. Lewinskyto ’ Ambassador Richardson, 

rlz~correct? 

ii3j A Correct. 

Q And then there is a note, it looks like up at the 

I::itop. It looks like, “Mona -what does this mean?” Right? 

[I61 A Right. 

ri7] Q 

ilt3i 

Do YOU recoanize that writina? 

A Yes: - 

1191 Cl Whose is it? 

t201 A Ambassador Richardsons, ’

Q And then at the bottom, it says, “BR - She wrote 

/::ithis note before we spoke last week. Just a thank-you.” And 

[23]tm ’ assuming, its ’ kind of squiggly. but Im ’ assuming thats ’

[24]yoU? 

(251 A Yes, thats ’ me. 

Page 32 to Page 37 olcstafr 

: 5 : to her the first hme. And so when it went rrto his in-box 

$ 

be. 1 

: 6: and he read it, he was confused because he wasnt ’ sure if 

;-.this was her saying 

: 3 ;And so he just aske tJ 

ou know, no to thejoo. or what it was. 

what does this mean 

,: 3: basically it crossed 

Q 

in’ the mail that we got t. 

And I just satd 

::3; So, ou were indicating tha: you thought she sent 

: 1: : this to you guys be Y ore - 

:;-; ‘

I??! Aa Before. -- you offered her the job? 

:14: A Correct. 

[Is; Q All ri ht. 

i16] BY MR. LgRNER: 

1171 Q But you think now on November the 3rd an offer was 

I 1 a ! extended to her? 

I191 A Yes. 

I201 Q Okay. And so it would have to have been either the 

[21 Iweekend of the 1st or 2nd, or the mornin 

122;the Ambassador spoke to 

[ 2 3 j wanted to extend an offer 

1241 - A Correct 

izsj Q Thats ’ very clear, okay. 

Page 36 

;;I 

A Yeah. 

Q 

[3]after - 

But when you say you received this significantly 

I41 A Yeah, it was a hard copy. I mean, it was in the 

f 5 1 mail, in an envelope. 

j76idoesnt ’

Q Ri ht although it is dated November 3rd. Now. it 

necessari 9 v mean that it arrived - 

ts1 

Aa th:no. 

t :~~recollection that you received it - 

a few days after that. But you have a 

ill! 

i121 A0 Rght. ’ SI 

f131 A yea ;1 

nrficantly after Novernbar the 3rd? 

ii 4 1 through. 

, but it takes a long time for the mail to come 

Its ’ typically - because it comes into a central 

r 151 place and they lo 

ti6]sometimes we 9 

most letters and things like that. So, 

e 

Cl71 BY t&. BlEWEd;: 

thin s ou know, two weeks late. So. 

[ia] Q 

tls]more exhibits. 

Now, Im ’ going to go ahead and show you a couple 

r201 To clear the dutter, we are done with this one. 

r 2 11 Were ’ actuallv done with this one. 

i22j A _ Are we done with-this one? 

1231 Q 

[24]oee 

No, Im ’ going to ask you one more thing on this 

t251 A Are we done with this one, too? 

(11 

t21 

131 

I41 

Q Yes. 

A 

Page 37 

151 

161 

171 

rn1first 

c-1.----. 

r91 

1101 

identification.) 

BY MR. BIENERT: 

0 If you reverse those and look at the one underneath 

t ;hi;.one? 

illi A Okay. 

1121 Q I guess what I would ask 

tis]memo, whgh -y&at number IS that, tv 

ou to do is look at this 

tha s MS-g? 

1141 

I151 Q 

116]entry on MS4. 

And then also direct your attention to the last 

ll71 A Okay. 

I181 Q And once youve ’ looked at those, let me know. 

(191 

I201 

ytn;;;eviewed the documents.) 

I211 Q Now, this is a memo that you would have - 

MR. LERNER: 

IZ;also. just to 

Perhaps also just the other document 

et a full feel for it. 

1241 Ml. BIENERT: Thats ’ actually a couple days later. 

f251So. I want to look at that later. 
3724 

BSA 

Page 38 

Mona Sutphen, 5127198 XMAXJ7!7) 

Page 41 

;$RTykw 

Q In ter ms of the first one, MS-g. this is a memo 

: that yz- s% it to the Ambassador, correct? 

Correct. 

Q / And you are addressing two topics, correct? 

._ A Correct. 

1’ Q And the second topic is indicating to the 

2 Ambassador that she has declined the position. i 12. A Correct. 

1 Q So, th[s would have been done short1 afler you 

i i $ j were lc:d by Ms. Lewlnsky she was not taktng the JO -g ? 

_.- A Correct. 

1:4; Q Now, in terms of trying to date the time of this, 

i 15; there ;s no date on the memo. _ - 

[li] A Right 

il71 Q But just sort of calling your attention to the 

11s lfirst section, which IS on an unrelated person, Ollie Olivas. 

[ 191 there ts a reference about two-thirds of the way down about 

[:olsomething that had been sent on Friday, January 2nd. 

121: A Right. 

Q 

If:;after the - 

So, would you agree that this would have been sent 

1241 

(25: Aa After - 2nd? that. And then - Im ’ sorry? 

[II 

Page 39 

A Right. No, corn+ 

Q 

I:ion Exhibit 4 thats ’ a call from - 

And then direcbnp Fur attention to the last entry 

I represent to you 

~4 1 that the D. tineman,, that is an address or a residence where 

rslMs. Lewinsky somebmes stays. 

[61 A Oh, okay. 

r71 Cl So, that is a call from a Lewinsky-related number 

~9 1 to your extension. 

[91 A Oka 

lo! Q On K e 5th of January. Do you believe that that 

I 1; would have been the call that she would have told you she was 

121declining the job? 

131 A Yes. althouah its ’ shorter than I would have 

iiijexpected. But. ” 

Cl Do you believe there could have been more than one 

I i 2 i call, or perhaps some messages? 

A There could have been, eah. I mean I again, I 

{ii) remember, or at least I think that every Ime I lnltiated a’ 

r 

[~slcall to her and she was presumably calling me back. 

Q Well actual 

i:y;beain with. You sh&d I aatthenextone. 

and perhaps Mr. Lemer was right to 

i22j - 

[231 

f241 

[251 

A Okay. 

Q You II notice there. these are records of pages. 

A Uh-huh. 

Q This is from Monica Lewinskys ’ pager, and it shows 

Page 40 

Illthat at 854 a.m. on January 7 

I 2 1 “Please call Mona Sutphen at 

131 A Right. 

[41 Q Do you recall leaving such a page? 

[51 A Yes: 

[61 

I71 

0 Why wouldp have left the page? 

A 

Q 

Tha was a ually after she declined the 

1;; then does it ap 

Okay. So then, rf this was after she dec aed, 

f! 

o&ion. 

[lolthe 5th orthe 6pe th.or somewhere in 

ar that she probab 

3; 

declined on or around 

ere? 

1111 A 

ilzi 

Yeah, althowh it could have been - yes. 

2 I;~u%%?%%%#i~i~ ‘ the week though, 

1: : ; Friday, the 2nd as well 

!t;;+hn ,,h, Q 

possibly. 

Okay. And then why did you page Ms. Lewinsky on 

L.“‘-..- . _... 

A Well when she declined, we got into a discussion 

i:ilabout whether or ndt she could call - she wanted to call and 

[ 19 1 thank the Ambassador in person. And you know, I figured he 

1201 

~2 11 R 

robably wouldnt ’ want to do that. And so I said, well, you 

now, hes ’ very busy; why dont ’ I talk to him and find out if 

to have time to take a call, because if we do that 

a time in advance to make it happen. And I 

ack to her on whether or not it was 

OIC-Starr 

[il Q So you think that was your call paging her to let 

I 2 1 her know whether or not -- 

I31 A Yes. She then asked me to page. She said if you 

14 Idont ’ get through on my telephone number, vou can leave a 

rsipage 

:bl BY MR. LERNER: 

!7l Q 

,>i 

L _ A 

;;; she give you a page number7 

191 a is-t)lis our handwriting? 

ilOi A Yeah, t K ats ’ my handwriting. 

Iii; BY MR. BIENERT: 

1111 Q And by “that”, thats ’ on Exhibit IW-2A. Theres ’ a 

r 13 1 pager number written at the top? 

1141 A Correct. 

il5i Q 

ilslher? 

When do you believe you would have gotten that fro 

1171 A I got that from her in one of the previous 

118 1 conversations, but I dont ’ remember exactly which one. 

I:i;interview? 

Q So, it wouldnt ’ have been at the time of the 

I211 A No. 

1221 Q 

i23i 

It would have been in a later call? 

A No, no. It was a later conversation. 

I241 - BY MR. LERNER: 

(251 Q Did you recall a conversation with the Ambassador 

111 in which he indicated to you that he wanted you to call 

Page 42 

[2 1 Monrca Lewinsky and find out what the status of her 

[ 3 1 acceptance or rejection of the job offer was? 

A Yes. At some point, I dont ’ remember exactly what 

I:jday he called and said you know whats ’ the story with 

rslMo&za Lewinsky. He tiad been hivin a conversation, he said 

[ 7 1 he had been having a conversation wit ?l Rebecca Cooper about 

relwhat we were going to do in terms of restructuring the office 

rglwith her public affairs component. 

I101 And I said, I dont ’ know. And he said, well, you 

I 111 know, we have to find out what the story is, because, you 

[ 12 1 know, its ’ been a long time and she has to make up her 

[ 13ldeciston. make a decision one way or the other; call her and 

r14lfind out, you know, she cant ’ have an 

[ 151 let us know what shes ’

Q 

8 oing to do. 

more time, she has to 

&, I said, okay. 

[I61 

A 

Do you ave any idea when that conversation was? 

Obviously it was before this. I dont ’ remember if 

I:;; it was right before the holidays or not. 

[~g]December-January time. 

It was somewhere in 

[201 Q 

121lsome - 

So, it could have been just before January 5th or 

A Well he was away for awhile. So it could have 

I::l]been in late December. And then I went away a$ well 

1241 ma have had that conversation in 

So we 

r2slan d then I just kind of waited to do *l 

ou know, late De&ember 

. Or, it could have 

a 

Page 43 

111 been, it could have been in the first part of January, like 

[z]on the 2nd. 

[31 BY MR. BIENERT: 

Q Two more topics and then were ’ done. Did you have 

/i/agn ?conversatlons with Vernon Jordan in December 97/January ‘

@8y .-, -- 

171 A Its ’ possible. 

[El Q How so? 

191 A We bumped into him on the Delta shuttle at some 

[IO 1 point when we were coming down to Washington. 

0 

I :: iget a job fir an 

Any discussion in that conversation about trying to 

body or Monica Lewinsky? 

1171 ;G, 

L--I 

.6 

i!idid you have an other conversations with emon Jordan? 

.&her than that possibly bum 

VP 

ing into one another, 

[I61 A t!o. 

Q 

I:lior arranging for, or connectin 

Would you have been involved in either setting up, 

[lg]Ambassad~ R$rdson and t ‘

any phone calls between 

emon Jordan in that timeframe? 

[201 

Q 

$ I Richardson and Vernon Jordan in that timeframe? 

Did you attend any meetings between Ambassador 

I231 A 

Q 

No, I did not. 

Do you have an 

ii:; were meeting and, if so, what t K 

knowledge of whether or not they 

ey were meeting about? 

Page 38 to Page 43 
3725 

e-3 Mona Sutphen, 5127198 XMAX(8.4, 

Page 44 

A I have knowledge of a meetin 

imeeting ’ they had sometime in Janua 

Q I will represent to you 

; that indicaE that was January 6th. 

Okay. 

5 : Q 

--,was? 

Do you know what the subject matter of that meeting 

A I have no Idea. 

-. Q 

: : -White House? 

All right. Then, finally, do you ever call the 

--, A Oh, yes. ?. 

.--, Q Who do you call at the White House? 

::?: A Usually -- well, I call a lot of people at the 

- 4 ; National Security Council, but I assume you mean the White .- 

; 5 i House prooer? 

;:61 ’ 0 Yes. 

A Sometimes people in the chief of staffs oftice, 

i i;i usually relatively lowdown people in the Oft& of 

r~i:Administration sometimes. In the chief of staffs office. 

ijoiNot too many people, I suppose, I guess. 

:>?I Q Do you ever lace calls to the White House for the 

r?71Ambassador .--, so he can talk P o someone? 

1231 A 

!24! Q 

No. I dont ’ place calls for the Ambassador. 

Do 

iz 5 1 speak to the Press .c! ent at the White House? 

ou know whether the Ambassador ever calls to 

Page 45 

iii A Yes. At least I think so. 

121 Q Im ’ sorry? 

13; A At least I think so, es. 

:4; Q Do you know how r hose calls are placed? 

151 A 

Q 

Usually lsabelle will lace them. 

[61 

; 7 ; President? 

To the President? C?r in order to get ahold of the 

i :z i ever 

Q 

recall 

So. its ’ a supposition on your part. But do you 

any instance where you either were present when 

117 1 Ms. Watkins laced 

[ 18 ] President or P old 

a call to the White House to get the 

ou she had or anything like that? 

I191 A 

Q 

I c&t recall any speci5c instance. 

Do you know - whether Ambassador Riiardson ptac+s 

I:iithe cell himself whether he has Ms. Watkins or whether be 

1221 has someone else do it - do ou know what number is used to 

t231get ahold of the President at L e White House? 

1241 

t251 

; Id:;; know what number IS used. 

Ill 

121 

Page 0 

MR. BIENERT: Thats ’ all we have. Thank you. 

(Whereupon, at 1255 p.m., the proceedings were 

t3)conctuded.) 

141 

t..** I 

CERTIFICATE OF COURT REPORTER - NOTARY PUBLIC 

ilSj 

1191 7HfZ 

DISTRICT OF COLUMBIA 

i:y i My Commission Expires: 

122 I July 31, 2000 

1231 

;241 

125; 

Page 44 to Page 0 
3726