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

3183 

. . -.-_- 

JENNIFER 

SAUBER. 

OFFICE OF THE INDEPENDENT COUNSEL 

Date of trmscnption 2/g/98 

- 

On below date Investigating Agents interviewed 

M. PALMIERI, Also present was her attorney, RICHARD A. 

The interview was conducted in SAUBER's office at 

1001 Pennsylvania Avenue, N.W., Washington D.C. 20004-2505. 

PALMIERI provided the following: 

PALMIERI, date of birth November 15, 1966, place of 

birth Pascagoula, Mississippi, Social Security Account Number 

1-4 graduated from American University in 1988. She 

currently resides at 

. 9 

_ home telephone- & work telephone _ 

_, White House pager __ 

PALMIERI has been employed at the White House since 

1994. From 1994 through March 1997, she was the Special 

Assistant to the Chief of Staff, LEON PANETTA, and from March 

1997 until present she has been the Deputy Director of the 

Scheduling Office. 

PALMIERI advised that MONICA LEWINSKY was hired as an 

unpaid intern during the summer of 1995. LEWINSKY worked in the 

Chief of Staff's Correspondence Office in the Old Executive 

office Building (OEOB). PALMIERI had no.role in hiring her. 

PALMIERI's office was in the West Wing next to LEON PANETTA's. 

PALMIERI would see LEWINSKY on occasion, as LEWINSKY at times 

would accompany TRACY BOBOWICK to the Chief of Staff's Office 

with mail. 

visitor. 

LEWINSKY would wear an orange pass.as an escorted 

B 

LEWINSKY worked directly for PALMIERI for several days 

in November during the first government shut-down in 1995. 

PALMIERI, at this time, liked LEWINSKY and felt she was a good, 

competent, and careful worker. PALMIERI needed help answering 

phones. She would clear LEWINSKY into the West Wing, and, 

LEWINSKY would be an escorted visitor. PALMIERI could not recall 

if she did, in fact, escort LEWINSKY during the work day. 

PALMIERI was shown WAVES records which indicated that she had 

cleared LEWINSKY in on November 15, 16, 17, and 18, 1995. 

PALMIERI agreed that those were the dates LEWINSKY worked with 

her. 

Investigation on 2/6/98 at Washington, D.C. FileY 29D-OIC-LR-35063 

SA 

by SA Date dictated 2/6/98 
3184 

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

29D-OIC-LR-35063 

Continuanon of OK-302 of JENNIFER M. PALMIERI .on 2/6/98 . Pane 2 

PALMIERI advised that during the government shut-down 

the President came to the Chief of Staff's Office several times. 

The President had rarely visited this part of the West Wing prior 

to the shut-down. PALMIERI-explained that the President 

"wandered" around the West Wing at this time because of the shutdown. During his visits to the Chief of Staff's Office, the 

President would speak with LEWINSKY. This was an exchange of 

pleasantries. PALMIERI advised that this was not unusual, -as the 

President is friendly and says hello to-everyone. PALMIERI 

stated that at this time she became concerned with LEWINSKY's 

behavior. %EWINSKY was giddy about being in the West Wing and 

about meeting the President. LEWINSKY was also like that,with 

HAROLD ICKES, GEORGE STEPHANOPOLOUS, 'and PANETTA. PALMIERI was 

concerned that LEWINSKY would. say something; embarrassing or in 

some way bother the President, but LEWINSKY never did, in 

PALMIERI's presence 

In December 1995, LEWINSKY moved t& the Legislative 

Affairs Correspondence Office as a paid staff member in the-East 

Wing. LEWINSKY had a blue pass at this time and was an 

unescorted visitor in the West Wing. At that point, PALMIERI 

would see LEWINSKY about once a week in the West Wing. They were 

not friends, aild did not socialize. 

PALMIERI stated that individuals at the White House 

were concerned with LEWINSKY hanging around the President too 

much. LEWINSKY had the reputation of being nclutchy.fl Senior 

staff members of the White House became worried that an affair 

between the President and LEWINSKY had begun. ,PALMIERI never saw 

an incident that lead her to believe this, and she never heard of 

one from another employee. However, this was the general 

speculation that an affair could be ongoing, and staffers were 

worried. PALMIERI recalls probably speaking with TIM KEATING, 

Legislative Affairs; SUSAN BROPHY, Legislative Affairs (now in 

Lisbon, Portugal); and EVELYN LIEBERMAN about this. This group 

wondered if there was actually an affair or just rumor. PALMIERI 

may have discussed this topic with HAROLD.ICKES and LEON PANBTTA 

as well. 

After LEWINSKY was moved to the Pentagon, there was 

relief among the senior staffers that she was gone. People at 

the White House were generally happy she had moved as they viewed 

her as a problem. PALMIERI did not_ know who had moved LEWINSKY. 
OK-302a (Rev. 8-19-94) 

3185 

29D-OIC-LR-35063 

Continuation of OIC-302 of JENNIFER M. PALMIERI .on 2/6/98 . Page 3 

PALMIERI saw LEWINSKY at the White House three more 

times after she went to the Pentagon. First she saw LEWINSKY on 

November 6, 1996, at the South Lawn event after the 1996 

Presidential Election. Then once in the West Wing Basement, and 

once in the West Wing Lobby waiting for an escort. Both times 

she asked LEWINSKY what she was doing there, and both times 

LEWINSKY replied that she-was there to see Presidential 

Secretary, BETTY CURRIE. This concerned PALMIERI as she -had 

hoped LEWINSKY would stop visiting the West Wing. PALMIERI told 

Deputy Chief of Staff, EVELYN LIEBERMAN that she had seen 

LEWINSKY in the West Wing. LIEBERMAN was upset, but PALMIERI 

could not remember what, if anything, LIEBERMAN said. PALMIERI 

believed this may have occurred in December 1996. 

. 

PALMIERI believed that LEWINSKY and CURRIE were 

friendly. She often saw them chatting at CURRIE's desk. 

PALMIERI was shown a diagram of the 1st floor of the 

West Wing. PALMIERI marked this in red ink. This diagram is 

attached to this FD-302 and incorporated by reference. PALMIERI 

described her office space in the Chief of Staff's Office area, .,

and its location in relation to the Oval Office. PALMIERI stated 

she believed the door between the Oval Office study and the 

Presidential Dining Room is probably locked. PALMIERI knew that 

this is not proper access to the Oval Office. The proper routine 

is to be cleared in by BETTY CURRIE at the main entrance to the 

Oval Office. 

PALMIERI was shown a series of photos for 

identification.purposes. 

She was shown color photo HB-2846 and identified the 

following from left to right: ANDY BLOCKER (Legislative Affairs, 

(L-A-1, departed); CHRIS WALKER (L-A. current); STACY RUBIN 

(L.A.); ANN JOHNSON (left White House employ); MIKE WILLIAMS 

(L-A.); ANN CATALINI-SINCLAIR (living in San Francisco); and 

LEWINSKY. Photo taken January 30, 1996, probably at PAT 

GRIFFIN's going away party in PANETTA's Office. 

Photo 48-4652 - black-and-white photo dated 

November 17, 1995, in Chief of Staff's Outer Office: GENE 

SPERLING (National Economic Council Director), HAROLD ICKES, 
3186 

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

29D-OIC-LR-3506.3 

Continuation of OK-302 of JENNIFER M. PALMIERI .On x/6/98 

. Page - 4 

President CLINTON, BARRY TOIV, ERSKINE BOWLES, and MONICA 

LEWINSKY. 

Photo HB-4655 - black and white photo dated 

November 17, 1995, outside PANETTA's Office, left to right: 

LEWINSKY, SPERLING, STEPHANOPOLOUS, TOIV, President CLINTON, and 

BOWLES. 

Photo HB-4656 - black and white photo dated 

November 17, 1995, in PANETTA's Office, left to right: SPERLING, 

LEWINSKY, and President CLINTON. 

Photo HB-4658 - black and white photo dated 

November 17, 1995, in PANETTA's Office, left to right: LEWINSKY, 

MARTHA FOLEY, SPERLING, and President CLINTON. 

PALMIERI stated that she had not been instructed by 

anyone on what to say at this interview. 

request for this interview, 

After receiving the 

PALMIERI told her superior, STEPHANIE 

STREET, and then spoke to CHERYL MILLS, Associate Counsel to the 

President. PALMIERI did not talk about her testimony. The 

President never spoke with her concerning LEWINSKY, or the 

ongoing Whitewater investigation. PALMIERI advised that White 

House staffers follow the story in the newspapers, and talk 

amongst themselves about who is going to the Grand Jury. 

PALMIERI stated she did know that OIC investigators were 

interviewing TIM KEATING this same day. 

PALMIERI further advised that she newr spoke to either 

VERNON JORDAN or BRUCE LINDSEY about this matter. 
, / ‘

arches for Potential, Eve~tn~ in JVhst ‘~~ 
3188 

Jennifer Palmieri, 2/24/98 

Grand Jury 

Page 1 to Page 68 

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 
3189 

BSA Jennifer Palmieri. 2/24/98 

Page 1 

UNITED STATES DISTRICT COURT 

FOR THE DISTRICT OF COLUMBIA 

.- ________________ x 

.- 

:I !n re: 

:L GRAND JURY PROCEEDINGS 

.- ;; __________-__ ___x 

: 

:: 

i; 

Grand Jury Room No. 4 

United States District Court 

gn, N.W. 

i; for the District of Co1umb.i 

(1: 3rd 8 Constitutll 

1:: Washington, D.C. 20001 

I?: Tuesday Februa 24 1998 

The testimoriy of JE&lIFt?R MARIE PALMIE 

I ii j n the presence of a full quorum of Grand Jury. 97-2 

[~zmpaneled ‘ on September 19. 1997. commenung at 

;;i;be ore: 

_. 

r1r:: 

SOLOMON WlSENBERG 

MARY ANNE WlRTH 

;;cj ’

DARRYL JOSEPH 

!nt Counsel 

Zounsel 

:nue, Northwest 

Washington, D.C. 20004 

:I? :I was taken 

1 ‘ 147 p. m., 

Page 2 Page 6 

[ll 

f 2 : Whereupon 

Jl?NNIFER MARIE PALMIERI 

I:$as called as a witness and after having been duty sworn by 

I 5 -the Forecerson of the Grand JUIY. was examined and testified 

itias follotis: 

(7: EXAMINATION 

[e: BY MR. WlSENBERG: 

0 Would you state your full name for the record. 

[ :I; please, and then please spell our last name for the record? 

A 

I :i j P-a-l-m-&-r-i. 

Jennifer Marie almlen and fi s spelled ): . . . 

113: 0 And thats ’ pronounced Palmieri? 

(14: A Uh-huh. 

Q Ms. Palmieri m 

I: i &h the Office of lndependint E 

name is Sol Wise&erg and I am 

ounsel. I have no colleagues 

f I 7 :wth me right now. These are the grand jurors and this is a 

( 1 c :grand jury court reporter. 

Before we 

ii ,’ i We bit about our aut 

et started 

a 

Im ’ going to tell you a 

onty and iell you your rights and 

rz~:responsibilitiis as a witness before the grand jury. 

Ill ’ occasionally ask you if au understand what 

Iggirrn saying and Ill ’ askJo? for an audible response because 

124 $he court reporter can PI& up a shake of the head or an 

[zslun-uh or an uh-uh. All tight? 

I 11 have +med to you, you understand that you have to answer the 

[ 2 1 quesbons 

[31 R 

ut t;i;y. 

Q If you have retained counsel, the grand jury will 

I : i permit you a reasonable opportun. 

[61~ury roan tg consult with counsel. %o 

to step outs& the grand 

you understand that? 

[71~ 

181 

A Yes. 

Q You understand thev cant ’ be in here with vou. but 

i 8 j you can go outside - 

. 

[I01 A Right. Yes. 

Ill1 Q 

[12lthat correct? 

And I understand you have counsel here today, is 

[131 A Yes. 

[I41 Q Who is that? 

I151 A Richard Sauber. 

I161 Q All right. And how do you spell that? 

I171 A S-a-u-b-e-r. 

Q 

i::;That is. myself 

All right. We are bound b an oath of secrecy. 

1201court reporter. *WI 

m colleagues, the gran d. 

I h 

jurors and the 

a few exceptions which we will get 

[ 2 I 1 into we are not allowed to go and blab to the workI or to 

r221anybody what 

A res. 

ou say here today. Do you understand that? 

1231 

Q 

IZ;of secrecy. 

You, on the other hand, are not bound by the oath 

You can tell your lawyer, you can go hold a news 

_ ~._~. 

Page 4 

A Oka 

iy& a federal grand jury empaneled by a federal 

&%i portion ‘ of the order issued 

D.Cbtirwit which sets 

lave iurisdidion 

1 ioiand authority to investigate to the maximum &dent authorized 

;;i;k the Independent Counsel Reauthorization Act of 1994 

ther Monica Lewinsk 

( 13 1 obstructed ustice. ‘

or otirs suborned perjury. 

[ 14 ;wolated fe d 

intim d ated witnesses or otherwise 

era1 law other than a Class B or C misdemeanor 

115 :or infraction in dealing with witnesses,. potential witnesses, 

116 1 attorneys or others concerning the uvil case Jones v. 

r17:Ciinton.’ 

Do 

~:~:awfls 0 d 

ou 

er? 

understand y&at I just read to you from the 

I201 A Mm-hmm. 

1211 . Cl Yes? 

122: A Yes. Im ’ off to a bad start. 

Q Okay. Im ’ now going to read you your rights and 

i :: ; responsibilities as a grand jury witness. 

125) As a general rule, you understand that you have to 

i I 1 answer the questions we put IO you ano answer :nem 

l2itlUthfiliiY. .~. 

i31 . A Yes. 

Q 

I: i answer an 

But you have certain privile es. 

2 

question If a truthful answer to 8 

You may refuse tb 

rslwouid ten 

he ql;estion 

to cncnminate vou. Do YOU understa.ti that? 

A Yes. ’ . 

Q Its ’ the privilege against self-incmnlnation. 

A Uh-huh. 

[131 A Yes. 

Cl41 Q You do have other privileges in addition to the 

[ 151 ht against self-incrimination. Youve ’ got the attomey- 

(16) 2 tent privil 

“4. 

e. which means if I ask you a uestzon the 

[ 17 1 answer to w ich would reveal a communica 9. Ion you had with 

[I 8) your Lawyer ou would not have to answer that. Do you 

r1s1understand ix at? 

iZOi A Yes. 

I211 Q If a question I asked you im 

~zz~communications, you wouldnt ’ necessarily g 

inged on the marital 

ave to answer that. 

(231Do you unprst;;t,that? 

[241 

[251 

.:. Q But with the exception of those privileges that I 

-” 

Page 7 

1 iI confizfenceAoti~~.nt. Im ’ not encouraging you to do that. 

I21 

I31 

141 

I51 

i6i 

; ~%$%$~~$~~~. 

A Yes, I do. 

Q You are free to tell or not tell, thats ’ up to you 

I : i and your attome . 

19) A 4s. 

Do you understand? 

oicstarr--_. -. 

Page 1 to Page 7 
3190 

BSA Jennifer Palmieri, 2/24/98 UAXZ) 

Page 8 Page 11 

i! ltell them what goes on in the grand jury. but they also are 

[? 1 bound by an oath of secrecy. Do you understand that? 

[31 A Yes. 

[41 Q A court can require us or allow us to reveal - 

I 5 I could jssue a court order, a court can always do this in any 

I 6trnvesttgatron. can Issue a court order allowrn or re uiring 

[ 7 1 the prosecutor to reveal some grand jury ma enal. 

[ 8 I understand that? 

P 8oyou 

[ 11 amcular health reiated reason or anythrng iike mat, oon t 

12 1 i? esitate to ask. 

I31 A Oka 

I41 MR. WISENBERG: 

[5]over questionin 

All right. With that, I will hand 

161 BY Nik. WISENBERG: 

I71 Q Can you tell us your age, please? 

I81 A Thirty-one. 

A Yes. (91 Q And vour place of birth? 

[211 Cl Do you understand target as ILe defined it to you? 

1221 A Yes. 

I231 0 A subject would be somebody who is not yet at the 

(24 Itarget status, but the rand jury has serious questions about 

tzslthem. They want kn 4of an explanation from them. Theres ’

Page 9 

[I Isome susponyFs.them. Do you understand that definition? 

t21 

I31 Q You are not a subject. Do you understand that? 

I41 A Yes. 

Q Witnesses are somebody who the grand jury wants 

Izllinfonnation from about a subject that the 

t7 1 investigatigg. Dyo,~,ou understand that de ff. 7 ‘

rand ury ‘ is 

nrtion 

[El 

[91 Q Do you understand that youre ’ a witness? 

I101 A Yes: 

0 

I ::lor subiect that thev will never become a tamet. 

Do you understand we cannot gyarantee any witness 

il3i . A Yes. 

I141 Q BeFuse its ’ an unfolding investigation and we 

[I 5 Idont ’ knowAwha;;re,ll find. 

(161 

1171 Cl Do you understand that? 

I181 A Yes, Ido. 

t191 0 All right. You are here today pursuant to 

f2ojsubpoenaAls th$syrrect? 

I-711 

1221 Q 

[ 23 1 personally 

And did the subpoena call for you to be here 

or personally with documents, any documents? 

1241 A No, just 

0 Okay. F 

rsonally. No documents. 

I251 ou understand that you have to tell the 

. _ 

Page 10 

tljtruth? 

ISi 

A Yes. 

0 Do you understand that if ou lie to us about what 

(4 lthe law calls a.material matter that would 

i 5 1 against a ~rnin&;w? 

L perjury, thats ’

161 

iildurin 

Q Okay. You have a right to have ciear questions 

P 

the questionrng, you have the right to have clear 

(91ques ions from our questioners. 

I101 A &ka . 

Ill1 MR. WISENBERG: Your questioner has just arrived, 

i:siMs. Wirth has ust ‘ entered the 

Let the record reflect that my colleague, 

rand jury room. 

[141 BY ‘ MR. WISENBERZ: 

1151 Q And so along those lines, if theres ’ any question 

(16jthat I ask or Ms. Wirth asks thats ’ not clear, that you want 

[ 17 1 us to repeat or to break down and ask in more coherent way, 

I 18 jdo not hespteFesdp so. Do you understand that? 

I191 

I:figrand ju 

Q All right. Do you have any questions about the 

3.. s ‘ authority or about your rights and 

122 I response 

I231 

i;tres(;.a grand jury witness? 

1241 9 And, again, if you need to confer with your 

tzslattomey or Just need to take a break every so often for any 

I101 A 

1111 Q 

[::;House. 

A 

I141 Q 

A 

And how long have ou been with the White House? 

I151 

Q 

I started in August o rm 94. 

1161 

A 

And how did you et your job in the White House? 

I worked for Leon IJ 

I:iiworking for him at the Office of Mana 

anetta for man years and I was 

ement and 

f 19 1 then he became Chief of Staff at the 

ud et and 

[zolwith him. 

&hit, House!an?I went 

[211 Q You worked with him outside the White House before? 

1221 A Uh-huh. 

I231 Q And what was our first job in the White House? 

1241 A 

1251 L 0 

It was Sfcial Lsistant to the Chief of Staff. 

Okay. nd for what period of time did you hotd 

Page 12 

I 1 J that job? 

121 A 

[31 AQ 

August of 94 ‘ until January of 97. 

g$ny.pa”,“,p; ;leyjgg gJa&$Y,;fg?.. 

i :i Bow@ became the Chief of Staff and I started my job in the 

r6lschedulin office in March of 97. ‘

. 

[71 % Do YOU know Monica Lewinskv? 

[El A Yes: 

I91 

t101 

1111 

r171vou met her? .--a,-- -- -- 

[I31 A She was an intern in the Chief of Staffs 

[ 14 I conespondence office. 

il5i 

t161 

AQ i;y as an intern. was she paid, do you know? 

[I71 Q 

A 

And how long did her intemshi last, if you know? 

As I recall Im ’ not sure at wha P 

I :i i there in the summer but she was there in the summer and the 

point she got 

tzolearly part of the fall,& my recollection. 

I211 Q 

A 

Okay. And where was her work station if you how? 

It was in the Old Executive Office Buitdi 

I:: i was adually in the correspondence office for the whole ?iZe 

t241House. You know. we have the Oftice of Presidential Letters 

t2sjfor the whole White House and within that we had a 

_= 

Page 13 

W?~ ondence office for the Chief of Staff but it was all 

12 ~wlulm he same office. You know, it was ali in the same 

13 1 racm. So she was over there. 

$er? 

Q Okay. Thank you. Did you have any role in hi 

I61 A Oh, as an intern? No. 

I71 Q Do 

A We x 

ou know who did? 

1 zi House interns are selected b 

, she was selected - you know, all the white 

tlojAbramson was the director o r 

the intern p 

the program rograrn-. a the time Karen and she 

t 11 ~would - we had sometim,es as many as four interns il the 

t131three or five, something kke that, and 

r12~correspondence office. I.m not exa~s~~u&t~~n 

t141them to the office. 

Q 

i:ziintemship? 

Do you know anything about how she came to her 

A 

!:&bramson 

I know it was someone - it wasproba%Karem 

but to be honest Im ’ not sure who old me at 

[lglone of thereasons ’ that%e&selnteadtiti 

_ 

Page 8 to Page 13 

- 
3191 

Jennifer Palmieri. 2124198 

Page 14 

f 1 lshe was an intern? 

I’1 A The first floor of the West Wing. 

Q 

1: 1 sat did you sit? 

Okay. And where in relation to where Mr. Panetta 

A Well.,if you have a diagram I can show you, but I 

izlsat right outside his door. 

I71 MR. WISENBERG: We have a diagram. 

,FI, THE WITNESS: You do? How convenient. Here’s 

r9lone - is this - 

ilOl MS. WIRTH: That’s a blank. I’m trying to find 

i 11 janother one. 

Okay. We’re just oin to mark this as Exhibit 

i it) JP-1 and this is a diagram o the 

1141 (Grand Jui Ex%%r?%l was 

marked for identification.) i151 

MS. WIRTH: I’m just going to show it to you and 

i:;ioive vou this green pen. If you could mark where your office 

No, I’m sorry - 

,‘ou can put your initials there maybe. 

.~ __ 

[18jwas.- - 

i191 

1201 

THE WITNESS:, 

MS. WIRTH: 

I211 THE WITNESS: Oka 

MS WIRTH: 

I%!Mr. Panetta _ _ 

Okav. x I 

I241 BY MS 

I251 Q 0 

._. __....... - ~‘ 3d could you mark where 

*S office was with hts initials? Thanks. 

;. WtRTH: 

Ikay. So for the record, you’ve marked a room, 

Page 15 

[ 11 that Mr. Panetta is in room 111, and th,at ou were in the room 

(2 ladjacent to his, directly to the nght of It. 8 you’re 

13 ] looking at this dragram. 

[4] A Mm-hmm. 

0 Now, did you ever see Monica Lewinsky during the 

i z i period why shguas an Intern? 

[71 

[31 Q And did she ever come into the oftice of the Chief 

[sjof Staff7 

A Yes. When she was an intern. she did not have - 

I:!;she didn’t have access to the West Wing without an escort, so 

r12jshe would come over with someone from the correspondence 

; I 3 ] office occasionally and drop mail off. Not every day, you 

: 14 1 know, put. you know, maybe two or three trmes a week. Qr 

i 15 1 sometimes I would go meet her in the basement and pick it u 

Q Okay. And ou mentioned a moment ago tha 

1:: i to be escorted. Who wou dP she had 

A 

bnng her in? 

Tracey Bobowick was her name and she was the head 

i : i 1 of the correspondence offr for us. 

Ifi) that time? 

0 And what type of pass did Monica Lewinsky have at 

A She had an orange 

ii: i for -you just have aaess to the 8 

ass, we call them. They’re just 

Id Executive Office 

[; 4 1 Building and the New Executive office Buildin . And then 

12s 1 there was a time when Monica worked in the & est Wing for a 

11; few days during the shutdown. 

i21 Q Okay. And approximate 

!!! 

when was that? 

A It was in November of ‘9 and I didn’t recall the 

i : idates exactly until thev were shown to me in mv FBI 

! 5 1 interview. but I thin k-gwas like the 15th throuch the 18th 

16 1 of November. something liki _.- e that. 

:7, MS. WlRTH: 0 

i 9 jdocument which isa W 

!kay. I’m going to mark as JP-2 this 

‘91 ,_I IG&XZZii ;bi No. JP-2 was 

I!01 marked foiidentification.) 

!I11 -.. - -- WlRTH: 

,171 

BY M,?;,! 

0 II ,.ZIU could look at that and tell us what, if 

1;; ,--,_,- r anvthing. : that document tells you about whether you waved her 

;Ir]ln_du_n ng the period of.time that you’re talking.about or 

t 1 s 1 whether you escorted her in. 

A Yes. It shows that I waved her in - do you want 

!::irne to say how many da 

1191 Q And wh~&$ei?%h$$. 

1131 A Okay. *It shows iha r I waved her in twice on 

(20 1 November 15th. twice on November 16th. three times on 

1: 11 November 17th and once on November 18th. 

Q And when you did that, do you have to go somewhere 

lii;to meet her and then bring her in? How does that wqrk? 

A 

If:isomebody gets cleared in, a visitor, and I think - 

Well. yes. How it’s supposed to w;t’kdr;,zat if I 

I 

Page 16 

Page 17 

[ 11 not sure and you alI could probably figure this out - but I 

12 1 think maybe she d$n’t have any pass at that point. I think 

[ 3 1 she didn t have an intern pass. 

Her intemshrp was, I think, offtuall 

I:!that point and so I think that she was deare J. 

over at 

in as an 

[siappointment, you know, where you just get an A badge and 

17 ] you’re just a guest. 

So when that happens, you have to 

ii I they’re escorted into. either the west lobby on w 

;%lherever 

rlolfloor or the west basement on the ground floor, and normally 

c I I 1 a uniform division person will be, a secret servrce 

[ 12 Iwill be posted there and they’ll call you and they’ll Ie ell 

rson 

tl3jyou that your guest is there and you have to.go et them. 

Q Now, you mentioned that dunng t 3, 

i :: 1 this period of time that 

e shutdown 

[ I 6 1 worked in ;he C$rerzf of .l 

ou’ve just described that she 

taff’s office, IS that correct? 

1171 

for 

iisj 

[I91 

t201 

I211 

t221 

t23tsat. 

t241 ‘_ 

t251 

Q Where did she sit? 

Aa Fey want me to show you on the diagram? 

A Shall I use her initials? 

Q Yes. And if you coutd indicate exactly where she 

A Okay.-Thatis-actuapy-whereIsatandtkat’sQ Indicating where your initials are and you put a 

Page 18 

[ 1~ box around them. 

121 A 

Q 

Yes. I put a box. Okay. She was right here. 

I :I her initials 

Okay. And you’ve indrcated. for the record, with 

in the same room where you were on the other 

tsjside of the~oorn~s~ that’s where she sat for those days. 

I61 

171 0 There’s a desk there? 

I31 A Yes, there’s a desk there. Or there was at the 

I ,_ 9 I ,_.. hme. .-. 

Q Was she the only intern who sat in that same office 

I :i i with you dfngi;:zown? 

i ::I office where your fi 

-shewas.-Hareld&keewao~ihe 

[ 14 1 possible that HaroM “4 

er is right now, room 108. and it’s 

ad an intern out there as well, but I 

tlstdon’t - I just don’t remember that. I recall R just being 

[l6]MOniCa and I. 

Q And who normally sat at the desk where Monica was 

~:~~sitting during the shutdown? 

i:zidesk. 

A Nobody, actually. It was just kind of an empty 

1211 Q the shutdown? 

A 

And what was her job duri 

Dun 

I::;days before the Wh “4 

the shutdown for at “9e ast for those few 

e House’s funding bill was passed, you 

124 ] had io be deemed essential staff to work and I was the only 

r251person in the Chief of Staffs office that was deemed 

C 

Page 19 

Page 14 to Page 19 
3192 

BSA _lennifer Palmieri. 2124198 

Page 20 Page 23 

: I whos ’ volunteering. I would encourage them not to have. to 

: !sta 

3; to, t: 

for that long, she certaniy wasn t under any ~ligallon 

: 4 : one 

ut she - I know that she certainly sta ed - I remember 

ni 

f 5 !came % 

ht tn particular I think she went ou ty to get przza and 

ack rn and It was pretty late, so I remember she was 

: 6 1 certainly willing to stay later. 

.I ‘

(I 

!91 A 

And the pizza was for the whole group? 

Yes. I thmk so. You know, we would send different 

: i 1 hadnt ’ started yet because of the shutdown, she wasnt ’ able 

[ :I to br+ hired, and i liked her, she was really good when she 

13 1 was In the correspondence of@,, she was always very willing 

I 4 ! to work hard, she was always wrllrng to stay late and, you 

15 1 know, whatever, and she was very conscientious. So I was 

rslpre 

3 

comfortable with her and so I thought she would be a 

171go person 

Q 

to help me out. 

j891familiar with other senior people besides the President. 

Now, you mentioned a moment ago that she was 

iID A Mm-hmm. 

1111 Q 

A 

Do any names spring to mind? 

Well, I mean just whoever was around at the time, 

i : : 1 which is the people who were nearby, which wouM be Leon 

114 ll-larold lckes, Geor 

9, 

e Stephanopoulos, you know, probably- ’

I 15 J I dont ’ know, just w oever was around. 

(16~McCuny around? Yeah, M&my. 

I guess - was 

Q Oka 

{:~~Milonica was stated r o get a job in the Dffice of Lagtslative 

You ~ntio~ a moment ago also that 

rlslAffairs. 

i2oj A Uh-huh. 

(211 Q 

122 1 position? 

Did there come a time when she eventually got that 

1231 A Yes. 

L24l _ ‘

(251 AQ ~~~~~~~~~~~~~~~~~~ 

.g ! kids out. 

Q Now. during the shutdown, did the President c 

: if i the Chief of Staffs office? 

::21 A Yes. he did. 

.:?I Q Do YOU remember approximately how many tir 

A Im ’ not sure exact1 

ii:idunng the trme that Monica was t 6, 

but ‘ I remember ma 

r 

b6 - 

[ 161 hmes. Something like that. 

ere, maybe three or our 

II?) Q 

A 

And when he came, how long did he stay? 

He woutd come in - you know, we ware in the 

I :“,i reception area and he would came in there and he might just 

tzotchat for a couple of minutes and, you know, either then 

(21 ~promed in to see Leon or, if Leon wasnt ’ there, ha woutd _ 

122 J ust. you knovy. ask me, you know, well, whats ‘ gor 

1231 1. eon around, IS he on the Hill. But it was a very ozt%? 

I.741 You know. there was - like I said, there was a lot 

t2slof people that were teft back at the White House who were 

ame to 

nes? 

Page 21 

! 1 jjust kind of sitting around not doin anything and ha 

rzlcartainl wasnt ’ going up to the HI himself so he himself 

f 3 jwas jus! kind of waibn?haround an! you kdow waiting to get 

(4 tinformation back from e HIII. Ands0 ’ he wandered around 

island chatted more often than he normally would because he 

161 normally wouldnt ’ have the time to do that. 

And can you tell us what you remember about those 

[I~lbecause it was unusual for the President to coma to our 

t~z@fice to bagin with and. obviously, you dont ’ want people 

[ 2 3 1 bothering hrm or. you know,, being too chatty or famiktr with ! 

[24 1 him. And she was very exerted to meet hrm. It was m I 

12s 1 ifnpression that it was probably the first time she aver ); ad. 

-. -_-- 

Page 22 

And so she was kind of gidd 

iiiwas concerned you know I kind J 

and bubbly and JO I 

- remember just kind of 

t3lcringing. thinking. like, oh,God, ‘ is she 

14 lsomethrn stupid. And she didnt ’ ou St 

oing to say 

R 

now I mean. it 

tslsaemad ne but I was concerned &cause dhe was a little too 

! 6 1 familiar. Noi just with him, but with a lot of the more 

17 Isenior staff, tOo. You know, I would prefer that interns 

ruljust sit there and answer the phone and not chat. So - 

Q And did you spaak to anybody about that, about your 

1 :z jconcems that youve ’ just described? 

;;$No. 

A Did I speak to anybody about that? At tha time? 

1131 Q 

A 

Andtbeother opteNot that I reca 1p. ” I mean its ’ possible I might 

! : : ) have said somethin to Leon Panetta about it or its ’ posstbls 

I kind o~remember him maybe rolling his eyes at 

i 

r:stthat Leon - 

I 17 1 me, you know, like watking b her, bacause she w&f answer 

/ 

( 18 1 the phone realty thee and 

tlsjmean I didnt ’ sag any%ing icause I was embarrassed because 

wasnt ’ really his style I 

tzottrn ’ th6 one who rou 

tz1 Idont ’ remember that ? 

ht her there, so I did not say - I 

1 

Q 

sad anything to anybod . 

I::idid you select her in partiiula 

When you say$oure ’ the one tt!at brought her there, 1 

A Yes. I did select her. You know she was getting 

I:: i ready to start a job at Legislative Affairs and i knew she 

Page 24 

(ljthink it was right after the shutdown. 

t21 Q And that would be December of 95? ‘

131 A Yes. 

~:~located, if 

Q And for that position, where was her work station ’ 

ou know? 

I61 b: 

Q 

ft was in the East Wing. 

I71 

ta1time3 

And what type of pass would she have had at that 

,” ,_.... _. 

t:ZlWest ’ Win 

A A blue pass, which would give you access to the 

1111 8 Wtihout an escort? 

r12i A Right. 

1131 Q 

A 

And do ou know what her duties were in that job? 

She wo M 

I i l I letters from members of Congress. 

ad in the correspondence office, answenng 

Q 

I:tlsee her ap 

And when she got that position, how often woutd you 

1 

roximately? 

I181 

Q 

Oh, I would see her in the haltways and stuff. 

1191 In the West Wing? 

I201 A Mm-hmm. 

I:: i I want to ask m la 

Now could I - excuse ma for just one saccmd. 

er one question. 

1231 MS. &lR%: Sure. 

MR. WtSENBERG: 

ii: i enter, if you co&d just knodc at tha door. 

When you come back, before you 

Page 25 

111 

121 

131 

Q Is there anything that you need to add to any 

I:;answer thaJ yot&e given previousty? 

ICI 

11 ’

-Q -cjj;gy I think when we took our break we were 

iiitalking about Ms. Lewinsk 

I slstation was located. And r 

s ‘ new job nd where her work 

believe you test&d that she 

tl~tgot~at~binla~~~r~95or~~~- ‘

A No I think it was - I think she was actually 

~~~~setected for the job before the shutdown but because they 

tl3lwerent ’ able to hire, she had& started. 

0 All right. And I think you also were telling us 

i::fthat you dg sebhzh$_ she got her new job. 

1161 

flf ’ 0 And I believe you said in the West Wing? Yes? 

1181 A Yes. Mmhmm. 

t191 Q And how often? 

A 

if!;week, son&hi 

Oh, you know, I dont ’ know. I mean, maybe once i 

if:;know. 

Q ~~~~~~ know what she was doing there? If you 

A 

f::;peopte all the time coming and going frqm their office, just 

Not really, no. I mean, I would - you know I see : 

.__. - _ -- ._~ 

Page 20 to Page 25 

- 

OlCStarr 

- 
3193 

BSA Jennifer Palmieri. 2124198 XWXIR 

Page 29 

: know. I saw her come into the West Wing at that *zme and she 

- didnt ’ work there any more and I saw her on the rcoe line I 

1 i: otier places. I mean - 

(2‘ Q 

A 

Where in the West Wing dd you see her? 

I would see her - I%? seen her near - I would 

i :;s.fe her in the hallway like goin 

/ j;West Wing. I would see her at 9 

from the East Wing to the 

he mess. I would sea her - 

[ 6; I saw her a few times by Betty Cur&s desk outside the Oval 

(?;offict. 

19: 0 

A 

Was she talking to anyone at that time? 

Sure. You know, I presume she was talking - I 

1 :~~wouM see her talking to Betty quite a bii As far as when 

[ 11 lshe was in that room. You know, there are always usually 

Wlpeop k around there. ou know, Nancy Hemreich sits there, 

[131 00. and at the time S r ephen Goodin would normall be around. 

I 14 1 But mv recollection is when I would see her. norma r ly she 

talkin to Betty. 

Q &her than BeXy. did you ever see her with anyone 

Page 27 

11 lcan kind of envision that. I dont ’ even know if Ir!’l ‘

12 1 imagining it to be honest, but I wouldnt ’ be surpnsad if I 

131saw that, too. 

[41 Q 

A 

But you have no positive recollection. 

No. I mean other than the times I saw them 

outtalking in the Chief of Staff& office. 

i71 0 During the shutdown? 

181 A 

Q 

During the shutdown. Yes. 

Did 

I ; z 1 saw her in the Wes 1 

ou ever speak to her on any occasion when you 

i ;; i Legislative Affairs? 

Wina when she was in the Office of 

- 

(121 A Oh, Im ’ sure I did. Yes. 

1131 Q Do you have any positive recollection of any of 

( 14 1 those conversations? 

A Not really. You know,. just to say hello, how are 

/ :z; ou doing, you know, hows ’ the new @ going. that type of 

; ;;;!MQ Did she ever discuss the President with you? 

A Probabl 

Itijagain I think that after 

. 

K 

I think she - during the shutdown, 

e left - you know, one time when 

! I I 1 he w&Id come by and afler he let you know, we walked out 

[zlof the room and 

12 3 1 believe the Pres ,k! 

ou know, she was like. oh., m gosh, I cant ’

ent was Just hens. sqmeth m+ke that 

124 1And. you know, I think I mght have said some hing to her at 

[ ~s~some point like. you know, you realize that youre ’ really 

Page 28 

! 11 lucky to be here during this time because normally the 

! 4 ! President doesnt ’ - you know, hes ’ too busy and does$t have 

~3@ne to..you know, come and chat w7th people. So I said 

( 4 1 something to the effect that it was unusual probably. So 

: 5 lyou know, she seemed excited that she was able to be there. 

[Ei Q Other than that ~tion. any other 

G 7 1 cpnversations with her about the PresuIent a! any bme, 

i 2 !cRher during the shutdown .or when she was in her permanent 

I ellob? 

~:~1spe@icall 

A 

x 

I dont ’ remember - I dont ’ femembe~ ;t#hing 

You know, its ’ possible. You know, I 

I :: ~~~~slble t at I might have, I just dont ’ remember anything in 

i:3jpartKUlar. - 

Q And other than the possibilii that youve ’

i : :/discussfl a moment ago, that 

; ; ; ; the President in the area of Be 

ou~&,~~n her talking to 

A Right. 

xy - 

il91 Q - do 

119 1 seeing her with the lJ . 

ou have any o@er recollection of ever 

A 

resident at any bme? 

Oh I saw that - 

ifyithey hugged wheia he hugged Ie 

ou know. that thing on CNN where 

iszlthe - the day after the election. 

r on the rope line after 

I was there and I saw 

[ z,)that. And I remember - I mean, I didnt ’ uFErnmh+r ‘ it on 

[I 4 1 my own, but when I saw the footage of i 

;zslthlnking. oh. yeah, I saw her come III and I saw her at-you 

s. remember that . 

.--1 

I191 A Yes. 

Q Okay. 

i:Fiapproximately? 

Can you tell the grand jury when that was 

I221 A Well. you know, Im ’ not sure what you mean b talk 

rz3;around the White House exactly. I mean, what do you mean /I 

[24lthat? Like someone - 

y 

[Z5: Q Talk about Monica and the President. 

Page 30 

I:; 

A Can I o outside? 

MS. VvIRTl% Yes. . 

[31 

L!Ms. WIRTH: 

e witness was excused to confer with counsel.) 

.~. 111 

Q I believe the question was - go ahead and answer. 

IZiDo you re~mber the question? 

[I ‘

I think it was -what was the uastion? 

I8i Q The question was something 9 Ike dd there come a 

[gltime - 

I::; ha 

A 

pened 

When there was talk. Yes. And basically it 

rlzlof P heshut #d 

ou know, almost immediately in the f%st few days 

own~Jike1~ 

rlz!behaved inap 

bejustkilblof 

11 I ! honest. I can IP 

mpriately and, ou know, there was - and to be 

recall exactly w K en It started but just kind 

tlslof an uneasiness about - like her being too familiar. 

Q And the inappropriate behavior that 

i::ijust now, was it anythi 

A 

beyond being too famllla ” J . 

ou mentioned 

1181 Not that “9 ever saw. 

Q Andwere there 

~$~was hanging around the West p 

la who were concerned that she 

ing too much? 

i2li 

I221 

1231 

1241 

I251 

-A- Yes. 

Q 

A 

And do you remember who that was? 

SpeMically, Evelyn Lieberman. 

Q Dd you ever speak with her you& about that? 

A Yes. 

Page31 

rlslseen her and, you know, didnt ’ like the way she behaved. 

I161 Q 

A 

Do you remember when that conversation took place 

I thin it was - I kind of remember seeing Evelyn 

i:iiin casual clothes, to my recollection. so I assume 1 must 

[lslhave been an 

1201 Q thatsstrmJsr. Which was heweekandoftheshw? 

r2ii A Yes. I think it was the Saturday. I think it was 

i;;jthe 18th. 

I231 Q 

A 

And did she give any reason for why she said that? 

I::ithan that: 

No. No, she did not. She didnt ’ say anything more 

OlCStan 

____ .- 

Page 26 to Page 31 
3194 

BSA Jennifer Palmieri, 2/24/98 X-II 

Page 32 

lli Q 

A 

Did you ask her7 

iZ1 No. I didnt ’ ask her. 

(31 

A Q We whx? I said - I think I might have said - I 1: jdon't know. I think i mtght have said something like “Youre ’

I 6 1 bein ridiculouq What are you talkin about?’ And she 

t7ldidn 9 offer me any explanatron. You & now, I dont ’ even know 

[ 8 1 if she said it again. And those probably arent ’ her exact 

tslwords, either. But - 

I101 Q And at that time. Monica was an intern. 

[ill A Right. 

1121. Q 

rlsljob. 

And you knew that she was about to get a permanent 

A Yes, but what I think she meant by that when she 

i ::;said “I want you to 

[ 16 1 want her out of the 

et rid of her.” is she meant like I 

& 

[ 17 1 Evelyn. 

est Wing. Which is not unusual for 

She - even when she - even before she became the 

t 1s 1 Deputy Chief of Staff and she was the Deputy Press Secretary, 

tlslshe was something of a hall monitor, if ou ~111. 

You know she would like - s e drdn t lake anybody 5 I. 

$f;in the West Wrng who didnt ’ bebng there because, you know. 

tnz~theres ’ a lot of people who will just like try to walk by the 

t23lOval Office and hope to see @a Prasicfent. 

I::;didnt ’ belong and she didn t like interns, or staff members 

And she certainly drdnt ’ like Interns in there that 

Page 33 

L 1 lfor that matter, whose skirts were too short or whose blousea 

12 Iwere too low cut or. you know, and she had no problem walkrng 

13 1 up to somebody she d never met tn her ltfe and like send them 

14 1 home because their skirt was too short. So it was not out of 

t51character. I guess, for her to do something like this. 

[61 Q Is that the only conversation you had with Evetyn 

~7 1 Lieberman about Monica Lewinsky? 

A Probably not. But - because, you know. after that 

1:; happened you know onca Monica was permanently installed. 

[ 10 1 there was- ’ you know, rumbli 

[ 11 labout her han ing around the % 

s about, you know, cdncem 

P 

al Office too much. So at 

[ 12 1 that point Eve yn was the Deputy Chief of Staff. she was 

rl3llight across the hall from me, we were relatively dose. so 

[ 14 1 it IS conceivable to me and probably even likely that we 

(1s 1 would have talked about it again, but I dont ’ remember a 

[ 16 1 specific conversation. 

I171 Q Other than Evelyn Lieberman. were there other 

ple who were concerned about Monica hanging around the 

I:iiKst Wing too much? 

A 

:Zjof a general 

Yes, I think theta was. I would say there was kind 

- I just picked u almost like a general 

t22~concam ou know. she wou 

1: 3 1 and, you .z 

b walk - she would be by Betty 

now. I would notice. for instance. that it seamed 

124 Ito me anyway that Nancy Hemreich woukfn!t talk to Monica, 

tzslwhich seemed to say something to me, that like Nancy did not 

Page 34 

! 1 lapprove her being around whereas Betty, you all have probaMy 

(2 ; met Betty, and shes ’ a very friendly. open non thats ’ nice 

[ 3 1 to everyone. So there ust ‘ kind of seem et/= 

14 1 feeling from Nancy an d 

to be e general 

Evetyn - \zn$tw, they just dtdnt ’

[ 5 1 like how she was ahvays 

Q 

hangi 

It;rnind as a 

But no one other % an Evelyn Lieberman springs to 

61” 

rson who expressed a concern? 

You know - not - no. I mean, nobody - no one - 

[ii I cant ’ imagine who else it would be that was really you 

110 1 know - it was something that Evelyn would do, thais ’ just 

(1 I 1 kind of her role, that she made to be her role, anyway. 

Q Did anybody ever express a concern or a worry or 

I if 1 appear to be worried about an affair between Monica and the 

[ 14 1 Presrdent? 

A I 

;:651what I told the F 8 

uess what I would say - and I think this is 

I after much consternation because ks ’

t 17 1 hard because I know the next question is going to be, well, 

[ 1s lwho said that and I cant ’ remamber. Id ’ say that there was 

rlsldefinrte~? eneral rumors 2 oing around through, 

velyn and the Of&a o Y; 

ou know. the 

t2otChref o S affs off~ca via 

[ 2 11 Legislative Affairs where Monrca worked, just kind of a 

tzzlgeneral feeling like shes ’ kind of - we use the word dutch 

t23jwhich ouve ’ all probably come to learn is somebody who 

t24larounJ 

K 

trres to hang around tha President too much. And 

anga 

tzslthere was concern about her just hanging around Bettys ’ desk 

Page 35 

; ; land. you know. why IS she there and. 

;: jbe there. Just like - you know, alrnos 

ou know, she shouldnt ’

r. 

! 3 1 President. 

kke haunting the 

141 And then there would be people who would speculate 

! 5) beyond that well. ee. do 

lslhavin# an affair. E? ut ,y z 

ou think that means theyre ’

ou now, no ones ’ ever said to me I 

i71s.a~ t em come out o the Oval Ofhce. I saw her go in alone 

(8 1 or something like that. 

I91 Q And you yourself, dtd you ever see anything that 

[ lolwould lead you to believe that there was such a relationshtp? 

:111 A No. 

[I21 Q And did you ever hear from anyone else anything 

I 131 specific that would lead you to believe that there was such a 

t231 Q 

A 

Do you remember when that happened? 

Mv memory is being there in the summer and being 

Iz:ithertin a weekend in the summer and somebody.telling ma 

Page 36 

I I I that. 

I21 Q Summer of%? 

i3i A I uess it was the summer of 98. ‘

i:;time? 

Q das she still employed at the White House at that 

t61 A 

Q 

I guess. I dont ’ know. 

t71 Do you have a memory - 

iiibein 

A You know, I just dont ’ - I ust ‘ remember tt 

a 

a weekend and it being hot. to be c, onest. I dont ’ - 

[ loland was very - ou know its ’ a ve 

MR. WIgENBERC: Let X 

vague recollection. 

e record reflect that 

I::iMr. Bennett and Mr. Joseph have enteredthegrandjury 

[13lroom. 

[I41 BY MS. WIRTH: 

[:ziyou that. 

Q You stated a moment ago you dont ’ remember who tr 

I171 A No. Its ’ possible that it was the Secret Service 

Pe 

rson themselves, to be honest, but I just dont ’ remember. 

i : i 1 ts ’ possible it was rumored to me by somebody who worked in 

t2olLeg1slative Affairs. I just don? remember. 

I211 Q 

[22jinvotvad? 

Do you know the name of the Secret Service aeent 

A No. I mean I presumed this might be what Ofticer 

1:: ; Fox talked about, but I dont ’ - I think if he came down 

tzsj himself and toM me this just happened I would remember thaf 

Page 37 

t 11~0 I think it was from a third source that I heard it, it was 

12 1 not from scxnebod 

Q Did;ou d’ 

who was dire&y there. 

I31 

t4jyOu recall? _ 

iscuss that incidant wtth anvone else that 

IS1 A No. I dont ’ remember that. My lawyer. 

161 Q At the time - 

A No, I dont ’ remember that. 

Do you recall ever having any conversatioos with 

about an affair 

A I dont ’ recall that, but it% possible. He is a 

I::ilikety suspect if you will, for someone that I would have 

tlsltalked to about that. 

IIs1 Q Whois he? 

A He is - he was at the time the staff director for 

I:~~LegislatiieAffairs. 

1191 Q Svhewast201 A Hes ’ in the private sector now. 

1211 Q He was above Monica in tha chain? 

I221 A Mm-hmm. Mm-hmm. 

Q And just tell us the best you can whatever 

~~:~recoltection you have of speaking to him, if there is 

rnsjany. 

.-.-_ ~~~ - 

Page 32 to Page 37 OlCStatT 

- 
Page 38 

III A I just dont ’ - I dont ’ have any specific 

[ 2 1 recollectron other than - I mean, Tim is somebody who I 

[ 3lwould speak with many times a day so - from 94 ‘ to 96 ‘ I 

{ 4 lcertainly thank that at some point, you know, I probably sard 

[ 5 1 like, “Hey. whats ’ the deal ith Monica? Shes ’ hangrng 

tsraround all the time.” You k w ow. 

Q So you think you robably had such a conversation 

iii miaht have had such a conversa e ton or youre ’ sure you had 

3195 

BSA 

Page 41 

i dont ’ - 1 don? recall really talkrng to Leon 

He wasnt ’ a brg - you know, he wasnt ’ one 

.~. 

t 9 1 suzh a conversation? 

[lOI I would sa I robably had such a conversation. 

1111 ;Y MR. WISE&f!RG: 

I121 Q Pardon me for interrupting. Let me ask a couple of 

t13lthrngs. If I understood you correctly, you said that there 

[ 14 1 are a couple of thin s. At first there were people talkr 

. t15tabout the amount o 3. trme that Monicas ’ hanging around s he 

[16]OVal mA, IS that correct? 

Page 39 

Q Okay. 

i:ijust answered this - 

Is that an office that - and 

,IS that an office that Mr. Kea ty 

ou probably 

ng was 

[ 3lrn. Office if L islatrve Affarrs? 

I41 yes. Yes. 

IZjspeculati 

Q Okay. Were you one of the people that was 

“% 

about whether or not there might be an affair? 

r71 

Q 

Was I one of the people speculating? 

181 

A 

Yes, you said - 

I was in conversations where other people 

Ii z; speculated about it. I dont ’ recall myself ever speculatrng 

Im ’ not trying to imply theres ’ anything wrong with 

_ __-- 

Page 48 

MR. WISENBERG: Okay. Sorry. 

BY MS. WIRTH: 

Q Is Susan Brophy someone you may have spoken to 

i 4 1 about this? _ 

r5, A Yes. Shes ’ another person in Leaislathre Affairs 

isithat I spoke with a lot. Its ’ possible: 

171 Q 

I B I have? 

Is that also probably youre ’ sure or you might 

f :,ilikel ‘

A That is not - I dont ’ feel as - I feel less 

t1t lwha r 

of that than with Tim. I think thats ’ probably - 

was the ra e? 

(121 Q 

A 

$%I. you can - 

_ (131 

1141 Q 

I liked your ranr: 

iisjhave - 

You have a de rnrte memory, probably, you might . _- - 

A 

;:76iMight have. 

Might have. I would say might have with Susan. 

Q What about Evelyn Likeberman? Anything more 

i : i &ecific than youve ’ already discussed? 

1201 A 

[alher. . 

No. No. Just I would say maybe might have with 

I221 Q What about Harold Ickes? 

A I dont ’ recall ever discussin 

i::;lts ’ possible but I just dont ’ - I don? recall 

Q’ 

9 

this with Harold. 

hat. 

1251 And what about Mr. Panetta? 

A Mm-hmm . .. . . 

Q And is there anybody, else I havent ’ mentioned that 

/i 1 you have ry r~~llection of drscussrng it with? 

19, 

[ 12 1 that formed the basis for an 

[ I 3 1 affair between t_he and Monica Lewinskv? 

I141 A DO I remember - Im ’ not sure I understand. 

i:zlthis or - 

Q Anyone mentiooing any particular fact like they saw 

A They saw this or that? No. No one - I dont ’

I :z 1 remember anybod ever saymg to me I saw them, you know, in 

r1slthe Oval OtIice. f&. 

t201 Q 

[ 2 11 professional? 

And your relationship with Monica Lewinsky. was it 

1221 A Mm-hmm. 

t231 Q Did you ever socialize with her? 

1241 ._ A No. 

~251 Q Did there come a time when Monica Lewinskv left the 

Page 42 

I 11 White Houre? 

(71 Yes. L-I --. 

I31 .ij 

A 

And do you knaw why? 

I41 I dont ’ know why. 

t51 0 

I L I House? 

What do you know about why she left the White 

.-a- ----- 

1231 A No. 

1241 Q You know that she was asked to leave the White 

rzs]House? 

Page 43 

;:;House. 

A No, I dont ’ know she was asked to leave the white 

I31 Q Do you know Jocelyn Jolley? 

I41 A Mrn-hmm. Yes. 

Q And she also worked at the office of Legislative 

~~~Affairs coyspori&fce offce? 

171 isi h And she was Monicas ’ supervisoR 

I31 A Yes, I guess. 

IlO1 Q Did there come a time when she also left the White 

I I I I House? 

A 

i::;realJy know. 

To be honest, I didnt ’ - yeah, she did. I didnt ’

, 1141 , l , Monica? Q Did you know whether that was at the same time ai 

--‘~_~-~~ ‘ __- A I have read in the newspa 

::76itime as Monica, but I didnt ’ know that at 

r that it was the same 

tRe. trme or 

11s Ididnt ’ - it didnt ’ make any impression on me, anyway. 

!:z:House? 

Q +3o~~~Wt7fte 

.--* ~~ 

1211 A I had heard that she wasnt ’ very good. 

f221 

I231 

1241 

I251 

_._ _~ - oicstarr -___ 

Page 38 to Page 43 
BY, 

3196 

Jennifer Palmieri. 2/24/98 

Page 44 

: Walker is the person who took Jocelyns ’ place - no, 

: actually - is that rtght? I dont ’ know if thats ’ ri 

Q 

A 

Do you know what happened to Jocelyn Jolley? 

No, I dont ’ know where she went. 

122: Q Did ou know that she was given a job at GSA? 

I231 A No, 7 didnt ’ know that. 

I241 Q Did pu team that Monica Lewinsky went to the 

j2s:Pentagon to work a er she left the White House? 

Page 45 

!:: A Yes. i_. Q 

i; fthe Pentagon? 

And do you know how it was that she got her job at 

I:; 

A No. 

0 Is there anything unusual about her 

[h.position at the Penta on rven you know, the fact 

etting that 

i7;was asked to leave t!e V&e House? ’ 

at she 

19: A I dont ’ know. 

Q Do you know any other staff members at the 

I i:iWhite House who were asked to leave and sot iobs at the 

i 1 I i Pentagon? 

_ . 

112: A No. I mean, I feel like I shoukl say that I 

[ 1;: have read that ha 

[ 14 Ithat and I wasnt ’ t 5: 

pened to Linda Ttipp. but I do not know 

ens 

115:so I dont ’ know. 

at the time when Linda Tripp left, 

[161 Q Do you know any otherFrsons dismissed from the 

j 17 :White House for the same reasons as onrca was? 

[lel A Well. I dont ’ know that Monica was even dismissed 

f1sjfrom the White House. 

Q Well, you said that at the time she left the White 

$iiHouse. there was a concern that she was hanging around too 

rz2imuch. corr~ct?.,~ 

I231 n Tes. 

I241 Q 

t25;reason? 

Do you know anybody else who was dismissed for that 

I 

---~- ..~~ 

Page 46 

;;i A 

Q 

Im ’ sorry. for that reason? No. 

f 3 i the White House art he time Monica &ft? 

Do 011 recall anythin about the reaction around 

t:f joccasions 

Q Can you tell us how many times and on what 

x 

ou can remember? 

I cant ’ tell you speciftcall 

1:: :I remember seeing her once in the wes fy 

how many times. 

basement of the White 

(14 1 House on the ground floor and I remember seeing her another 

[15$ma in the west lobby. I remember seein 

rlslthat event in November of 96 ‘ on the Sout ?l 

her coming in for 

Lawn. 

(17: Q 

IlSlagO? 

Thats ’ the rope line event you mentioned a while 

119) A Yes. 

1201 Q When YOU saw her in the West WIMI basement. what 

t2ljwas she doing? _ 

[2-1 ‘ A 

I231 Q 

She appeared to be waiting for an escort. 

In what area? 

1.24; A In the west basement, probably sitting on one of 

(25 jthe couches there. 

* I 

Page 47 

[II 0 Was she with anyone? 

[?I A I dont ’ remember. 

I31 0 Do you remember what time of day that was.7 

141 A It was normal business hours. I thank it was 

[ 5 1 morning. but I dont ’ know. 

I61 Q And 

I 7 1 waiting for an 

ou sard you saw her in the West Wing 

esco rly 

I81 A 

? Is that right? 

She appeared to me to be waiting. I think I 

~91 her what she was domg there, I think she told me that she 

( 1 o 1 was going to see Betty. So she seemed to be waiting for 

[ 1 I 1 Betty or someone to come get her. 

I121 0 Did ou see anybody speak to her on that date? 

1131 A Did lysee anybody speak to her? I kind of remember 

[ 14 1 when I saw her, her talking to somebody else, you know, 

[ lsjsomebody else 

[16]dOnt ’ recall anyt 

robabl just happened to be walking by, but 

in de rnttrve. 

I171 0 

R-% t'.- 

A 

At w at time of day was that, in the morning? 

t:i;dont ’ know for sure. 

It seems like it was in the morning again but 

j2ojthough. 

Im ’ pretty sure it was business ho&s. 

j211 MR. WISENBERG: Pardon me just a moment 

[221 We need to take a ten-minute break. 

[23i 

1241 

j251 

Ma the witness be excused? 

THE FOREPERSON: Yes she may. 

- tVViiness excused. Wb-ress riscalled.) 

Page 48 

[II BY MS. WlRTH: 

Q Ms. Palmieri ouve ’ just testified about three 

/:! instances on which you saw h onrca Lewinsky at the White 

I 4 I after she had batI the White House to ao work at the 

j 5 1 Pentagon. 

I61 A Yes. 

Q And the first one was the rope line on November 

Ii i 6th. approximately - 

A Oh I dont ’ know - I mean thats ’ the first one 

j:iisaid, I don! ’ remember the order in whichthey ’ happened. 

1111 Q But in anv event. after the election vou saw 

t12jthe rope liie an;~;;mr.reseottbatday. 

I131 

jlsjremember that. 

And what did she say? 

Page 49 

t11 A She said she was there to see Betty. 

I21 Q 

A 

I:;something 

And did rou sayhanything further to her? 

I mean. mght ave asked her howshewas. 

like that. 

Q 

i 2 i speak to her on that occasion7 

What about in the West Wing basement? Did 

A Yes that is k&t 

ii 1 ust ‘ less clear in rni mind and Im ’ pretty sure I sard hello 

( 

- I dont ’ know why but ks ’

191 o her. Actualty. no,, I think I remember saying hello to her 

flojand I think she had lust 

1 II 1 Itold her I liked her new. 9,. 

otten her hair cut or something and 

Q 

arrcut or something like that. 

I :$ i House to anyone e se on 

Oka? Ddr report her presence tn the White 

ose two occasions? 

A Not that I remember on the first occasion. Exarse 

i::irne. The occasion in the west basement. When I saw her tn 

[ 16 1 the west lobby. I told Eve n Ltebennan that she was there. 

I171 

A I don't rerr!ber.@T 

Q And what Id Eve n Liibatman aa , if anyth. 

I:i;said anything to me. 

0 be honest, I (r ont ’ thank 

1201 Q What was her reaction? 

A She - I went into her office I told her that, I 

i::ileft and she left her office shortly after thai 

t231 Q Was she upset when you told her this? 

I241 

1251 

% $ she upset? 

Page 44 to Page 49 OICStatT 
3197 

es. Jennifer Palmieri. 2l24198 XuAxrSI 

Page 53 

A Okay. This IS JP_4, 5 - I thank JP-3 and 5 are 

f ‘ the ‘ only ones that are simrlar. This is my office and thus 

:: ts Barry Toiv. That is Harold lckes Thats ’ the President. 

.X Thats ’ Gene Soerlina. That IS Erskrne Bowles. And thats ’

j ~~Monica Lewiniky. ” 

i. ‘ Q And thats ’ reading from left to right. And what 

;::occasion was that or what trme? 

A That was the ni ht - theres ’ the President eating 

::: izza That was the night that believe we sent Monica out 

;i/;Pogeipizza foreveryone. ’ 

r:ri 

Q During the shutdown. 

A Durin the shutdown. 

::‘ ’ L-d. BY MR. WISENBERG: 

Q And you went left to right except that Ms. Lewinsky 

Iifiis actually in the fore round. shes ’ a kttle to the lefl of 

I:E: Mr. Bowles in the PI, c? ure Is that correct? 

1::: 

Ilai 

2 p$gt. 

enme. you went left to right, correct? 

--. 

Page 50 

No. I mean. I dont ’ - she dtd rst appear to be 

i;sjMs. Lieberman? e s ’ 

1191 A Because - like I said before, that there were 

tzotconcems 

t21than in 

- you know, there had been concern about her 

around too much and I knew at that point that she had 

t22ileft &egNh. rte House, it had been rumored that she had left. 

tzstthat she had been, you know, asked to leave, so the fact that 

124 lshe was back hangrn out in the West Wing didnt ’ seem a good 

tzslthing to me and so. II! e I said before, Evelyn was kind of 

Page 51 

r 1 r the hall monitor so I re tied it to her. 

I21 Q Qka 

A I wa M 

gyou know if an 

ed out in the west lo &r‘ 

htrg came of that report? 

y a few minutes later 

i:iand Monica was one. I dont ’ know. I mean. she could have 

i slbeen in to see Be 

[ 6 1 point. 

Ry I dont ’ know where she was at that 

MS. WIRTH: Im ’ going to show you some phot 

iiiwhich have been marked Grand Jury Exhibits JP-3 through “B 

raphs 

. 

tsr So youll ’ see 3.4. 5, 6. 7.8 and 9. 

t101 Exhibits Nos. JP-3 

t111 

t121 

MS. WlRTH: And what Im ’ showirg you are Xerox 

[::!copies of photographs and next to them the actual 

t~slphotographs. 

And what Id ’ like you to do is just go throu 

i :t!one of them, read the Grand Jury exhibrt number an % 

h each 

tell the 

:19t 

%, 

rand jury what the picture is of.and who is in the picture. 

1191 nd. perhaps while youre ’ doing that, you mght hold up the 

t2olorgnal for them and ust ‘ point out what you see. 

t211 THE WlTNkSS: Oka . So JP-3 is 

121 MS. WlRTH: 

j23jfor us. please. 

Start w& 3 and go aI?he way through 

THE WITNESS: 

I:: ; in Leon Panettas ’ oftice. 

Okay. This is a photo that was taken 

Page 52 

1;; BY MS. WIRTH: 

ISi 

Q 

A 

And youre ’ holding up JP-3? 

Im ’ sorry. 

[ 4 iwho everybody is? 

3. Should I just go through and say 

I51 Q Sure. 

i:ip 

A This is Andy Blocker. I believe all of these 

ople - yes at the time, all these people worked at 

13 jegrslatrve Affairs. Thats ’ Andy Blocker. Thats ’ Chris 

f p r Walker. This is Stacey Rubin. Elisa Milsa You know him. 

( 1olThats ’ Ben Freeland. Ann Johnson. Mike hlliams. Ann 

11; Cattalini. And Monica Lewinsky. 

q 0 

[ :;iwhat that phot 

Okay. Readin 

ra h - when 9 

from left to right And do you know 

hat was taken what occasion? 

A %el? it says it was taken on January 30 

I:, ‘ 1 Ihave to believe that was Pat Griffins ’ going away party. 

1996 and 

I161 BY MR. WISENBERG: 

0 And you said You know him.’ that refers to 

I ii ) President Clinton? 

113: A Yes. This is the President Yes. 

t201 BY MS. WlRTH: 

Q Okay. Next. please? You can do them in a group, 

I$ iif you like if its ’ easier for ou. If there are pictures 

tzjtthat are d?icative of eac!r other. 

I241 Oh, okay. Yes. I think some of these are. 

ts1 ’ Q Just read the numbers out whik youre ’ talking. 

A Yes.- 

That appears to be the original photograph of JP4. 

Page 54 

111 A 

I21 Q 

It looks like it is. Says so on the back. Yes. 

A 

Also in your office? 

f::lefl to right Ba 

Also in m oftice. Oka 

Toiv hXonica Lewins 

And then this - JP-6 is 

BY ti. WlSENBERG: 

K y and the President. 

And what is the date on that? 

1141 Q Same date? 

ilSj A Same date. 

Q Okay. Did 

! :; ! Lewinskv movina to New Y 

ou ever hear anything about Monica 

ork? 

P 

Page 55 

tllassisting her in any way to get a job in New York other than 

r2nuhat youve ’ read in the newspapers? 

131 A 

Q 

No, I have not. 

Have you ever heard an 

!:iMonica Lewinsky was a witness in the P’ 

ng about the fact that 

(sIthan what 

aula Jones case, other 

171 I( 

ouveoread ’ in the papers? 

Q 

IiiLewinsky. fillin 

Have you ever heard anything about her Monica 

9 

out an affidavtt in the Paula Jones case’ 

[ IO 1 other than wha 

A F&r. 

ouve ’ seen in the papers? 

1111 

Q 

i::iintenriewed b 

And did you speak to anyone prior to being 

t14jtalking to the b 

the FBI about what you would say prior to your 

A 

81 in February 987 ‘

No, I did not discuss what I would say or what I 

I$membered about Monica. Certainly there has been a great 

t17ldeal of talk in the White House about the whole incident, the 

tle&uation as we call it. But lve ’ never talked to anyone 

rlslabout my personrret~wfftrerbein there. 

Q You advised your supervisor 

I:yibe speaking with the FBI? 

%l at you were going-to 

1221 A Uh-huh. I did. 

1231 Q And you spoke to Cheryl Mills as well? 

I241 .A Yes. 

I251 Q Did you speak to Cheryl Mills about the substance _ 

OlC-StaW Page 50 to Page 55 
I 

3198 

asA -_. Jennifer Palmieri. 2/24/98 __..^ .~_. 

Page 56 

- 

XMAX(10) 

Page 59 

[ 1 I of what you would be saying to the FBI? 

r-1 A No, I did not. No 

0 And what about prior to our testimony here today7 

1:: Have you spoken with anyone from the bite House about your 

[ 5: testimony here today? 

161 A I have not spoken with an 

(7 11 told a number of peo le that I would be K 

one about my testimony. 

181 Q Oka 

ere today. 

%iho have you told? 

A I tot J Stephanie Streett, who is my supervisor. 

(:iiMy lawyer told Cheryl Mulls. De u 

[ 111 explain to some people este a 

28 Counsel. I had to 

112 Abe at work today, so I to d Doug 

r 

hat I woutd not be able to 

osnrk. I think thats ’ It. 

[ I 3 1 Itold Nancy Hemreich I wouM not be there today and this 

[lrlwas why. 

Q The grand urors ‘ have a couple of questions for 

I:z;you. The first pertarns to n, e comment that you testified 

t 1 T 3 about eartier that Evelyn Lieberman made !o the effect 

(1s ]“I want you to 

A ces. ‘

et rid of that girl.’ 

1191 

I201 Q 

izljright? 

That comment was made during the shutdown? Is that 

I221 A 

CT 

Thats ’ my recottection. Yes. 

And what was your understanding of what she 

I:: I meant by that comment in terms of what you were supposed 

tzslto do? 

Page 57 Page 60 

Id ’ like to talk to my lawyer about that. 

e wrtness was exwsed to confer with counsel.) 

okay. So tf youll ’ say the question 

I:tiWing. was m understandin of that comment. 

(161 A ./uR~R: An 8 

THE WITNESS: 

what did you do? 

I told Monica that she - that it was 

i:llquiet and I didnY need her help and she should take the rest 

tlslof the day off. 

I201 BY MS. VVlRTH: 

I211 Q Dii you do anvil further in response to that 

ifithat. 

Q By people. In other words, you obviousty noticed 

A I noticed that. It made me uncomfortable because I 

i:ididnt ’ want her to be botherin 

9 

him. 

Q Okay. All righ . 

i z{ interaction with - do 

Anything about the Presidents ’

ou 

L 7 1 Is recall discussing that. 

recall - tet me go back Do you 

t 8 1 remember discussin 

You said it bothered you. Do you 

that with an 

A I don a dy 

one at the time? 

remember iscussing it at the time other 

;:ilthan the interaction I had with Evelyn Lieberman. in which 

I 1 I 1 she said to get rid of her. 

::21 0 

A 

Oka ._Butthatruas~ying&at~ 

Righ . 

: if; remember talkin 

Y I dont ’ remember saying it to - y. donY 

: islof in a watch an 8 

to anyone about it at the time. I was more 

see mode. 

Okay. Was there anything - Im ’ sorry, I cut you 

i22 jcomment? 

[?31 A No. 

I241 Q Did Monica come back to work the next day? 

I251 A No, that was - as I recall, that was the last day 

Page 3 

.--,~ . 

I161 A ldont ’ know. No. 

1121 BY MR. WtSENBERG: 

Q Okay. t .ust have a few 

~:~~understand you to say t c, 

uestiins. 

at she might no Ihave even been an 

0ii I 

fzotintem. Monica, during the shutdown? Technically? That she 

121 Irn. ht have been in some status in between internship and her 

trztst%job? 

1231 A You know, how we can find out. can we go back 

i2 i j look at theg pig;rz_s? 

f2Sl 

and 

, : A 

-i f pass she has 

If shes ’ got a pass on, you can see what kind of 

Yes. See, she has an appointment badge on? 

:3i Q All right.. 

A And Intern would have -when she was an intern 

t li she had an oran e pass. 

.oi Q &ay. 

.-, A So I think thts means that she probably had turned 

:s ;in her badge from when she was an intern and she got this 

i 3; other badge. 

::1i Q Okay. You sard that the President dun 

: : 11 shutdown would come In and chat wrth people in your ?Vhe o ce. 

: : 2 1 Do you recall that? 

-:3j A Yes. 

::I] Cl 

A 

Would he chat with everybody? 

There werent ’ that many people there. I mean, my 

/ i 2 1 recollection is it was just me and Monica and 

: : 7 1 know, obviously these i&ret show that on 

- well, you 

diirent times, 

; : ; ; pu,w~~~btgeo~$ or &ne, OtherT, mQht have been 

Q Did he appear to s nd an inordinate amount of time 

~~~{chattin~ with Monica as opposed o others during this time 

fzzlperiod. 

I231 A Yes. hedid. 

1241 

I251 ; 

Q AllhLWasthat ’

rrI 

mmmentPrlupoa? -.- 

A Was hat commented upon? 

Page 61 

t I IMonica during the shutdown that raised e 

d 

ebrowa, 

t2 Ianyone elses, ’ other than what you% to us? 

youn or 

I31 A Interaction between the two of them? 

141 

151 A0 ?i%Pi witnessedo 

161 Q That you witnes&.rd or heard about that raised 

[ 7 ]e ebrows among 

18 1 w K at youve ’ alrea d 

our&f or among others. Again, other #an 

y reported to us. 

A No. Im ’ not sure I reallv understand. I mean. are 

t ; 0 i you just sa ing is there an 

d 

ing else fhat I havent ‘ - 

I :: i came in and cha ed, but anyt ng about the v&&e four-day 

R#ht. An&~, about - not just about bvhen.he 

f 13 1 period or however tong it was, anything else that kind of 

114 J raised any eyebrows. either that you wrtnessed or heard 

I 1 s I about? An example would be was she seen going Into the 

11 .S 1 hallwa . 

f 17 lsomet !t, 

off the dining room? That would be an example of 

tng real1 unusual. Anything like that? 

fie) A 40. 

0 Okay. Anpmtngttavingtadowltbherdelivering 

~:~~pizza to the President? Lrke maybe - you said ou sent her 

121 tout for pizza. About her personally going in a lu? 

rztlit to him. 

delivering 

(::iif its ’ the 

A Oh. I dont ’ - I have never - I dont ’ even know 

er of suggestion, you sa ing that, I have 

tzsjnever - t I?w atnever entered my mind, i ut now that you say -’ . 

Page 56 to Page 61 OlCStan 
3199 

ESA Jennifer Palmierl, 2124198 

.______. 

Page 62 

XMAX(l1) 

Page 65 

1:. that. I think she did tell me that. 

iito hrm? 

0 Okay. Just that she had gone and delivered pizza 

!4 A Yes. Id ’ like to talk to my lawyer about thus 

is:because this never came u before. * _ 

16: MR. ,WlSENBER 8 : Sure. Sure. Knock when youre ’

he witness was excused to confer with counsel.) 

Okay. I think we were talking about - 

Illi A Pizza. 

112! Q - pizza and what she told you, what you remember 

ii3jMonica telAng you. 

It .ust kind of threw me for a loop because I 

I::;comptetely forgo 1 about it until now but I remember her - I 

[ 16lthink - m recollection as it is coming back to me now, I 

tl?]think may L she went out to get pizza, came back!n and we 

[ ~spvere sharing it with everyone that was around, I thank maybe 

[ 191st?e brou 

tzo jsitting ou ?- In front of the Presidents ’ office, it was late 

ht it down to gave a piece to Betty or whomever was 

[211at n‘ ht. 

(22110: CI?r 

I mean, I think the WAVE records show tt was like 

or sornethmg like that, and so I remember-then I 

f23jremember her coming back and being really excited like, oh, I 

[24 ]was there and the President was there and, you know, I went 

[25]in and gave him a piece of pizza. 

Page 63 

Q 

i : i about that? 

Okay. Anything other than that that you remember 

131 A No. 

Q 

~:~delivered it to him. 

Do~ou remember where she said he was when she 

A No. I think she said at his desk, but thats ’ the 

itiimage I have in my mind. I dont ’ know. 

I91 0 The desk in the Oval Office? 

191 A Yes. 

i :~&ivering 

Q How long, if 

61 

izza to Betty an r%I 

ou know how long was she gone 

the Preddent? 

I121 

Q 

I donY know. Sorry. 

I131 

A 

No ballpark even? 

I didnt ’ even remember it until you said it. I 

i::;just dont ’ know. 

Q Okay. Did you recommend her. Monica, for the 

1: t 1 Legislative Affairs job? 

[l?! A Yes, Idid. 

i14! Q 

A 

Okay. And whywas ’ that? 

Because I thought she was ood. I mean, the same 

izi: reason why I had her come and volunteer P or us for those few 

[ ~2 Idays. She was - you know, my experience with her, she was 

I 2 3 1 conscientious and she was very hard workin 

Q Is there anything about this s 4. uabon that makes 

li!iyou angry? The whole situation, the Monica situation. 

Page 64 

I:1 A 

1:; 

I3i 

Q 

Id ’ rather not be here today. 

Rather than that? 

A Id ’ rather not have hired a la er. No. I mean - 

14 1 M. Its ’ too bad. It seems like a big waste o 7. bme, but it 

(5 1 doesnt ’ make me angry. 

l&i Q Did you ever hear that Monica - I think what you 

; 7 : told us earlier was 

[ s 1 Pentagon kind of II! e after it happened, right? 

ou kind of heard about her going to the 

i9: A Right. 

[iO! 0 Did you ever hear she was sent to the Pentagon 

! : 11 because of poor work performance? 

A Yes, I remember that, too. I remember - probably, 

I i, ’ i again from Tim Keating that, you know, not only was - 

, ;4 1 know: not only these concerns about her hanging arou n%e 

i ~s!Oval Off& too much, but that the work quality .ust in the 

And so you could at(ribute that 

I cant ’ say that I recall that for sure. 

Okay. You said that you were - you talked about 

[ : 1 the times that she came to the White House after sne naa 

[ 2 1 to the Pentagon and you had asked her what she was doing 

[3lthere. 

i41 A Mm-hmm. 

Q Were you confrontational when you did that? 

i z i you saw hr there and asked her what she was doing there? 

iiioverty friendpj. 

I would not say I was confrontational. I was 

Q Okay. You said you didnt ’ hear an hrng about 

1 :ilfact that Momca was on a list of witnesses in the s aula 

[ 1 I 1 Jones case. Did you hear anything about or was there talk 

r12labout Monica as another potential roblem for the President 

[ 131 in connecbon with people talking a f! out the Paula Jones case? 

1141 In other words, as an example, anybod 

[ 15lsomething like “Theyd ’ better not find out about FJr. 

saying 

[Isjanything like that? 

ontca,’ 

I:iiMonica. 

A No. I dont ’ recall anybody saying anything 

Cl91 Q 

[20lanybody? 

Are you part of a joint defense agreement 

(211 A Im ’ not sure I know what that means. 

Q Oka . Thats ’ pically an agreement between 

i::lgroup of attorneys ?. or drfferen 1. wrtnesses involving a 

124 ]shZ_nng of infom3ation. 

t251 A Well, I have authorized my attorney to speak 

Page 66 

t 11 attome s representing other witnesses. He has spoken with 

12 1 Cheryl h. 111s. as I told you. Hes ’ spoken wtth Evetyn 

13 1 Liebermans ’ er and Ste 

I I 1 woman who wo L”m s for Davt If 

hanie Streetts ’ lawyer and this 

Kendall, Nicki Siegetman. I think 

isjhername: 

$ithink of? 

Okay. Youve ’ authortzed him. Anyone else 

Thats ’ all that I know of. 

All right. How about with anybody working 

I dont ’ think hes ’ talked to an 

Okay. And-you expect then r o - 

body with Bennett. 

I wouldnt ’ be adverse to him doing that. 

And youve ’ authorized him to debrief those 

I161 A 

Q 

Mm-hmm. Is that a joint defense a reement? 

I :i 1 he debriefed. for instance. vou men toned Ms. Milts before. 

It could be. And do y know whe#er or not 

,-~, 

I191 A Mm-hmm.. e 

Q Do 

i:ylthe general subje d 

ou know whether or not he spoke to her 

t22jthe other day? 

matter of your interview with the Bureau 

1231 A I think he did. Yes. 

1241 0 Okay. And I take it you expect that with respect 

1251 to these four people, you expect in a general way a 

B 

Page 67 

tlldebriefing wfth 

A 

ard to your testimony here today. 

fl necessarily I mean I would not - I think 

~~{wfll ask him to talk to Cheryl about it and I will not ask 

14 1 him to speak with anyone etse. 

191 Q 

A 

Okay. Im ’ not - 

Yes. Thals ust ‘ what my plan is. I dont ’ know 

!76;theymay-tous ldon G know 

rai Q We n&d vour ohone number at the White 

ou had that number? 

hone, but you just call the 

and someone will answer 

and say page Jennifer 

You dont ’ have a personal beeper or cell phone? 

(241 

1251 

A No Ido not. 

MR WISENBERG: Okay. Any other questions? 

OlCStan Page 62 to Page 
3200 

BSA 

Page 68 

Jennifer Palmieri, 2/24/98 

!ij rs;JR%%%RG: ”. All right. Thank you very much. 

i si Let me tell you that sometimes when people come to the grand 

[ 4 ljury. even eo le who feel the ve ‘ been here a long time - 

[5i ~HHEPWITNESS: I& one byT, actually. 

MR. WISENBERG: &ter the leave the 

i76iremember something that they had forgo en about. 

mi ht 

Y ust 9. tke 

18 1 Imentioned pizza and you remembered something you had 

f qlforgotten about - 

I101 THE WITNESS: 

MR. WISENBERG: 

Yes. That surprised me. 

And it might be something thats ’

i if 1 relevant or slightly inconsistent with what youve ’ said here. 

l I 3 1 If that happens, I would ask you to let 

[ 14 1 and have your attorney get in touch wi!h Ms. Wirth or wrth 

our attorney know 

I 15 I myself. 

[161 THE WITNESS: Okay. 

MR. WISENBERG: 

I :i iquestions ma 

All right. If there are no more 

the witness be excused? 

I191 THt!FOREPERSON: ‘

MR. WtSENBERG: 

Yes, she may. 

I201 Thank you very much. 

t211 

lELlh 

I::;in the presence of a full quorum of itie Grand 

““,“,“,“,“,“,” %%%~%?d.lh, taking of testimony 

[ 24 Iconduded.) 

ury was 

[2Sl 

l . . . . 

XUAXIZI 

___. - _~ - _.~_ ~~- 

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3211 

Leon Panetta, l/28/98 

Grand Jury 

Page 1 to Page 208 

1 

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 

- 
3212 

BSA Leon Panetta. 1128198 xM4xul 

Page 1 

Ill UNITED STATES DISTRICT COURT 

FOR THE DISTRICT OF COLUMBlA 

[‘]____‘_‘_________X 

r31lN RE; 

141 

I51 GRAND JURY PROCEEDINGS : 

161 

!71 

[8]-___ _----_--_ ___x 

[91 Grand Jury Room No. 4 

1101 United States Drshict ’ Court 

ill1 for the District of Columbia 

1121 3rd & Constitution, N.W. 

I131 Washington, D.C. 20001 

I141 Wednesday Janus 28 1998 

i :zi 

The testimony of LEON%A&TTA was taken in the 

resence of a full 

(171 8 eptember 19 19 I 

uorum of Grand Jury 97-2 

7 commencin at 930 am, 

I181 SOiOMOrj WISENBEjG 

* y$ggd On 

I191 BRUCE L. UDOLF 

[201 MARY ANNE WIRTH 

1211 STEPHEN JAM I--, 

1221 

1231 

f241 

[251 

ES BINHAK 

Associate Independent Counsel 

1001 Penns lvania Avenue, N.W. 

Suite 498 North 

Washington, D.C. 2@304 

Page 2 

(11 

[ 4 1 was called as a witness and. having been first duty sworn b 

[ 5 1 the Foreperson of the Grand Jury. was examined and 

I 2 1 Whereupon 

test 

I31 

if& 

( 6 1 as follows: 

LEON PANEl-fA 

I71 EXAMINATION 

(81 BY MR. WISENBERG: 

191 Q Good momino. Could vou state your name for the 

f i 0 i record, please? 

_ 

ill1 A 

Cl 

My name is Leon Panetta. 

And. Mr. Pan&a let me inform you - my name is 

i::iSol Wisenberg. first of all and Im ’ here with m 

(14 1 from the Office of Independent Counsel, May 

collea ues 

kne &h Steve 

[ 15rBinhak. and Bruce Udolf. who you met out in the hall; is that 

r 16 1 correct? 

I171 A Thats ’ correct. 

And let me start b 

i22l And 111 ’ also dsk-jw that when I ask you those 

r23jthings. if you can give us a yes or a no or a maybe - 

1241 

Aa That s fine. [251 - for the record. This is a federal grand jury 

Page 4 

I141 

1151 

So F yqudrderstand our authority in the matten 

[I61 Q of course, you have the privi 

?? 

against setft17rincriminati~. frttt understand you are an a orney? 

1181 

Q And you may refuse to answer any question if a 

~:~~truthful answer to the questron would tend to incrrnmate 

r2llyou. 

I-‘?] A I understand. 

Q 

: fii incrimination? 

And you understand the privilege against selfI251 A Yes. Ido. 

Page 5 

Q 

1; used against you by the grand lury or in a subsequent legal 

You understand that anything you do or say ccutd b.e 

-:-proceedm ? 

1. %, Yes, I do. 

< ‘ Q If you have retained counsel, your counsel does not 

i g. have the right to sit with you in the grand jury room but 

I- the grand ju 

-i:step outside r 

will permit you a reasonable op 

he grand jury room to consult WI .P h counsel if 

ortunity to 

; YOU so desire. Do you understand that? 

r:. ’

;:. -counsel. 

A I understand that. I am not represented by 

,__ ._._ .- 

1:;: 0 Okay. You came here by yourself today, 

1::: A That s correct 

Q 

i il i rules of secrecy covered in Rule 6(e) of the Federal Rules of 

All right. The grand jury is bound by certain 

rii:Criminal Procedure. 

I :i _ myself, m 

As a general matter, with certain exceptions 

[ls:are boun dy 

colleagues. the grand jurors, the court reporter 

by an oath of secrecy. We cant ’ go out and blab 

t2c 1 what youve ’ said here toda 

[2:: A I understan J 

Do you understand? 

Q 

i::go ‘ out, if you so choose, and tell the world about what you 

You are not bound by that oath of secrecy. You can 

124 jsaid today. You dont ’ have to, but you can. Do you 

~25:understand that? 

Page 6 

A I dont ’ think so. 

Vrgl%?s fair. . 

l4! 

11: 

A I understand. 

15’ Q Just an example of some of the exceptions. ff 

{sithere were to ever be a trial arising out of anythin 

12: 

(71 

131 

,Fi 

rand jury did, and you were to testify differently t 51 

this 

an you 

15: ave here today, that would be an example where your grand 

[ oijury testimony could be revealed. 

110: A I understand. 

0 There are certain categories of witnesses who come 

I:: !before a federal grand jury. known as subjects or targets, 

tl2:and Im ’ oin to read you thedef&innfrorn.tbeLlS. 

,I(. Attome& h&nual of a tamet. 

il5l .A target is defined 3s a person as to whom the 

[ 16; rosecutor or the grand.jury has substantial evidence linking 

r17! g. rm or her to the commtssron of a crime. who, in the judgment 

’ 

1 Ie : of the rosecutor. is a putative defendant.” 

1191 e ou understand that definition? 

1201 A I do. 

Q 

i::iundentand that? 

All right. You are not a target. Do you 

1231 A I do. 

Q A subject is defined as .A person whose conduct is 

i::;within the scope of the grand jury investigation.” Do you 

Page 7 

I 1 I understandAtha; ~$titiin? 

[21 

Q You are technically under the manual definition - 

i:ibecause thats ’ such a broad definiiion. you woutd be a 

tslsubject. Do you understand that? 

A I understand. 

il81 - - A Ido. 

1191 Q You understand that those are not set in stone, 

tzolthose categories: that we cannot guaranteethat you wiTi 

(zllnever beaxne a ta 

? 

et. 

[221 A I un erstand. 

t231. Q This is an evolvin invest’ 

rzrlrdea whatwe miaht find. You un % B 

ation, and we have no 

erstan that. 

i25j A I ijndentand. 

OlCStarr Page 1 to Page 7 
3213 

BSA Leon Panetta, v28/98 

Page 8 Page 11 

::i Q 

.: 1 correct? 

You are here pursuac: to a subpoena today; IS that : : served as Drrector of the Office of Management and Budoet 

roxrmately January through - January of 93 ‘ through 

A Thats ’ correct. 

0 Drd that subooena as* for anv documents? 

A No, it drd not. 

time today I or my 

: 1: 1 that you please stop us an 

: 1: ; agreeable to you? 

.._. 

.--I 

..jr 

.--, $ 

Yes it is. 

All right.. Do 

: : 4 1 responsrbrlrtres as Ive ’ read t r; 

ou understand your rights and 

;:si 

::61 t 2: lt? 

em to you? 

171 ‘ A Mav 9 ask one aueshon? 

ilei Q Yes. sir. 

12: 1 you give me A some Wthr? 

ards to issues of executiie privilege, can 

u ante on that? 

Q We 8ave not - what I can tell you is Im ’ unaware 

iii!of any - nqbody.frpm the White House has contacted us about 

t2rlno!rworking for the V!h. 

t: 3 1 an execubve pnvrle e issues regard 

de House, I can rr? 

you, but I cannot - 

[,-slin that regard. 

guarantee anything 

Page 9 

. . And if you need - if you feel that you need to 

ii ;step outside and consult wdh anyone or call over there, 

:31we II be ha 

R 

py to let you do so. 

Well, tf I feel that theres ’ a question that may 

i: 1 hinge on that. 111 ’ at least raise that - 

,61 Q Okay, all right. 

:71 - for purposes of discussion. 

!31 z 

:5i A 

lt$m;;ld are you, Mr. Panetta? 

[1Cl Q 

!I?] A 

And where were you born? 

I was born in Montere California. 

!:l! Q And can you tell us A. 

l:slis? 

at your current occupation 

I i: i things. 

A My current occupation is - Im ’ doing a number of 

I am a Drstinguished Scholar at the California State 

: : 61 University at Montere Bay. Im ’ also a consultant to the 

[ :: ]Chancellor of the Call r omra State University S stem. Im ’ a 

[ ; 9 1 Distinguished Scholar at Santa Clara Univen 

1 i9 1 teachrng there. 

4. doing 

I am also a member of the Board of the U.S. Stock 

ify;Exchange. and Im ’ a member of the Adviiory Board of 

122 1 Fleischman-Hillard, which is a public.r@ations firm. 

I231 Those are my principal acbvrbes. Im ’ also doing 

;:;;public speakrng. 

0 Is it fair you would identify yourself as a 

Page 10 

1 I 1 politician? 

[-I. ‘ A After 30 years involved in poliiics. I think thats ’

:3!fatr. 

I41 Q Youve ’ had a career in poliiics, correct? 

15; A Thats ’ correct. 

!61 0 Are you practicing law in the sense of - 

“1 A Im ’ not practicing at the present time, but I am a 

i g 1 member of the California Bar - 

tIEi 

Q Okay. 

A - and have practiced. 

I111 Q 

t:2]Administration; 

All right. You were a member of the Clinton 

is that correct? 

1131 A Thats ’ correct. 

Q Can 

ii: j were in theAClinton x ou tell us the dates, from when to when. you dmrntstrabon? 

1 ::inominated b 

I was first appointed by the President or 

the President to be Director of the Office of 

[ 1 E IManagemen r and Budget. That would have been soon after the 

t:4lelection. I believe it was in ea December that I was 

[ :o 1 nominated for that posrtion. an ?r 

t21lSenate. I believe. mid-January 

I was confirmed by the 

I221 Q That would be 1 ?I 

ust ‘ before the inauguration. 

93? 

A That would have been in 19 - Janua 

II:!December of 92 ‘ that I was nominated approved 

f-5; Senate - confirmed by the Senate in January of 9 ‘

. __, 

-- 

By the way, let me ask you, thats ’ commonly known 

.-. A OMB 

[I-i Q And those are the two 

1 I 8 j Director of the OMB and Chief of Sta rp 

ositions youve ’ hekj, 

. 

I191 A Thats ’ correct. 

Q 

iif i member of Congress? 

Before you were in the administration, you were a 

1221 A I was elected from the 16th District in California. 

[ 2 3; which is the central coast area of California, and my home 

~24 Iarea, and served in Congress for 16 ears e’ ht terms. I 

[ 2 s : think1 was actually elected to my nr r<e&%be%me 

Page 12 

I I ! that I was nominated to be Director of the Office of 

[2 1 Management and Budget. 

::;too. right? 

Q And you were chairman of a congressional committee, 

t51 A I was Chairman of the House Budget Committee and 

(6 1 also served on the House Agriculture Committee. 

[I ‘ Q How long have ou known President Clinton? 

A 

i:! up to Capitol Hill to - at the time I believe he was head of 

I met the Pres idy ent when he was governor and came 

[ IC { the Governors’ Conference and was presenting issues retated 

i 1 i 1 to education, and as Chairman of the House Budget Committee, 

112 ; I was asked by the leadershrp to attend a meeting in which he 

I 13; presented some issuesrelated. toe&cation 

r23j Aa Thatlmfeu s ’

I::imet him till then? 

- when you would have - you wouldnt ’ have even 

i 

Page 13 

t11 A Thatt.mnect ’

Q 

i : 1 OMB, until you 

Oka 

r 

. So you were not a dose friend at al until 

wen to OMB 

I41 A Thats ’ coned: 

Q All right. Once you joined the adminiababon as 

i ,’ 1 Director of OMB then how would you charade&e your 

17 I relationshio withhim? ’

1251 A Thats ’ a fair statement. 

Page 8 to Page 13 
3214 

BSA Leon Panetta, ll28l98 

Page 14 

[iI Q And there would be frequent Interaction then 

(2 1 between you and the Presrdent because of your role as 

I 31 Director of OMB. 1-1 

141 A Thats ’ correct. 

Q Would 

[lithe admrnrstration. bot X 

ou consider yourself now, having served in 

as Director of OMB and then as Chief 

[71of Staff, a friend or a dose friend of the President? 

(91 A I believe now, after servin 

[ glof OMB. but, in parhcular. as Chref of Sta 9t 

not only as Director 

r~olcould descnbe our relatronship as berng a 

I believe you 

friend of the 

[ 1 I 1 President. 

1121 Q 

il3jschool? 

By the way. where did you - go _ to college and law 

A Went to college at the Universe 

I:“sland also went there for law school. 

of Santa Clara 

Graduat e? 19SO - from 

[~s~undergraduate school. a political science major, and then 

(17lgraduated from law school in 1963. and then served in the 

i 1sjAnny for two years. 

Q 

:::;a nutshell definition o what you would descnbe as our 

Whenlou were Chief of Staff, can you just give us 

t21jduties as the Chief of Staff of the President of the Y. nded 

[ 2 2 1 States? 

A As you can imagine, the responsibilities of a chief 

I::iof staff are very large and ve 

1253are - the primary roles that I x 

encompassrnp. but these 

ad were as fol ows as Chief 

Page 15 

f 1 I of Staff: 

Number one to or 

I:ithink I was asked to t& Chie ? 

anize the White House staff. I 

of Staff largely to try to 

14 1 bring some sense of organization and discipline to the White 

t5lHouse staff. So, first and foremost, organize the White 

[ 61 House staff and provide a chain of command and discipline. 

Secondly, oversee the staff, basical 

1 lithe staff so that it would serve the President o 7 

coordinate 

the United 

[ 9 1 States. 

Thirdly, oversee the development of policy for the 

i :y! President, both on domestic and foreign affairs issues, and 

l IZ lensure that whatever briefings the President needs, that they 

f 13 1 are property developed for presentation to the President. 

I was, as a member of Congress, largely involved in 

I::icongressional relations as well so that I would deal with 

116jboth the congressional Leadership and members of Congress 

t17jwh0, because of my association with them, would often call me 

t1sjon various issues. So I did a lot of congressional relations 

119 lwork in that capacity. 

Also haven I:; jManagement and 

been Director of the office of 

Bu 8 get and Chairman of the House Budget 

r22jCommittee. I was very involved on budget issues durin 

I 

that 

123lr riod of bme, and so advised the President on many o the 

[ 2 4 1 udget tssues that he was presented with. 

(251 I was also responsible for overseeing his schedule, 

Page 16 

( 11 to set u a schedule for the President, and work with the 

12 jschedu & rs in making final decisions on that, and the 

[ 3 ] President. 

And then, lastly. I would periodically travel with 

[ “51 the President. One of the things I wanted to do was to 

[ 6 lensure that someone from the Chief of Staffs Office, either 

[ 7 1 myself or a Deputy Chief of Staff, would accompany the 

[ 8 1 President on tn s and control the trip. And I would 

[1ojresponsibi&y. ’ 

[ 3jperiodicall do at. but my deputies would also have that 

So that in a nutshell were some of the 

I ::; responsibilities that I had as Chief of Staff. 

Q I want to focus on the first part of your answer. 

[::iYou said that one of the thin 

9. 

s you were brought in to - Im ’

[ 15 ] not quoting you exactly,. but o improve,. perhaps, 

[ 16jorganization and discipkne and the chatn of command. 

I171 Was there a feeling that there had been 

(18 1 insufficient attention to those issues under your 

i 13 j predecessor? 

liy;Staff - 

A When the President asked me to become Chief of 

(221 Q Pardon me must a minute. 

MR. WISENBERG: Let the record reftect that 

I::) somebody opened the door and then closed it. 

I251 

(11 

Page 17 

BY MR. WISENBERG. 

121 Q Canyon. 

131 A When the President asked me to become Chref of 

I 4 I Staff, he expressed concern about the operatrons of the V&tie 

(5 1 H,ouse and that the operahons. he felt. were not suffiuenrv 

[6]disciplrned or organrzed to serve him In the most efficient 

! 7 1 way, and that one of the first requrrements he asked me to do 

18 lwas to try to organize the White House staff In a wa tha! 

[ slwould be much more disciplined and much more e ffy rcrent rn 

[ 1 o ] serving him. 

[ i 6 1 there was - for lack of a better term. there was not 

[17jsufficient disci line. 

t~s~offices in the & 

People would wander through the 

est Wing. They would go into the Oval Ofhce 

t15jor into the exterior of the Oval Ofhca wdhout oftentimes 

tzojany particular appointment. 

There were a number of eneralists. By that I mean 

i:::individuals that had no particular de ?i ned 

1231 kind of walking into meetings and givin 

role other than 

124 Itherefore, there was a lack of indivtdua i!r 

opinions,,and, 

who camed a 

[25]Sp&fiC job description oC.re+on&#y. 

Page 18 

[11 Q That sounds like a good job, by the way, to have 

[2 1 opinions and walk into meetings, 

t:~politics. 

A Theres ’ nothing like being a generalist in 

I51 flauahterj 

i6i 0 Im ’ sorry. Carry on. 

171 A And then, thirdly, the briefings for the President 

[ 8 1 would oftentimes turn into long meeti 

[ 91 not 

s because they were 

t lo j An cf 

roperly controlled or they were no “9 property re ared. 

so oftentimes discussions on issues, instea SPo ’ being 

I 1 i I kmited to a pefiod of time pursuant to a schedule co& 

[ 12 joften drag on for an hour or even two hours. And there was 

[13jconcem about that as+vel!. 

Page 19 

tt]Chtef ofStaff responsrbla for personnel and schedukn 

tljarena as well as somepdiqaraaa,3&t4a~ 

a 

(31 responsrb&tiis under that. 

111 would report to. 

So that everybody knew w o thay 

And then lastly a created a greater focus for tba 

i ~~President so that when h$ wanted to deal with a particular 

[ 7 1 issue, he was not doin a number of events that - 

MR WtSENiERG: Let the record reflect that someone 

1 iiopened the d&r and dosed it right away. Mr. UdoH is going 

[lo] to investigate. 

Ill1 BY MR.WlSENBERG: 

I121 Q Canyon. 

t131 A This was a little more of the White House you saw. 

1141 ILauahterI 

iisj And “we used to - and we would create a focus then 

I I 6 1 on trying to ensure that if the PMdent was going to do a 

t17jpart event, that that would be the event of the da as 

[ 18 jopposed to having a number of events and there p ore not _ 

I i 91 present a dear message to the Amarican people. 

_ 

IE~involved in. 

Those were really the primary areas that I was 

Q You mentioned 

~::~officas in the West Wing. Wha p” 

opla wandering around in and out o 

rzrldoing - 

do yw recall s 

what. if anything, to restrict access in t 

picaky 

rzsjWing? 

e West 

OlCStarr Page $4 to Page f9 
3215 

BSA _ xruY*1 

Page 20 Page 23 

11; A 

I? 1 made sure that 

I mean, the most important thing was that I had 

no one should just wander down to the Oval 

i 3 !Office unless a staff member was associated with a parttcular 

14 1 briefing. Or if, you know, we were doing somethi,ng on a 

rslpolicy issue,. I normall 

16 1 ought to go rn on a 

Indicated who - what.rndrvrduaIs 

po Y ICY bnefing to the President. 

So that if he was having a pokey briefing, I would 

ii 1 normally provide clearance as to who WOUM go in for the 

I 9 1 poll 

cty 

briefing. Or if the President was meeting with staff 

;lo]or tf he President was having an event. I would normally 

! 1 I 1 review who would be there for a particular event. 

And then when we would brief the President on - or 

I::isometimes prepare the President for an event, I would 

: 14 1 determine who would go in with me to brief the President 

t15jbefore an event. - 

0 I guess if you dont ’ have a system like that, its 

i :t; kind of natural for - 

MR. WISENBERG: Let the record reftect that Mr. 

I: i 1 Udolf as reentered the room alone. 

1201 BY MR. WISENBERG: 

t211 Q I guess if 

[ 221 natural for people to wan r 

ou dont ’ have a system like that, its 

to be seen with the President or 

f23jwant to get in meetings with the President. 

A You know, obviously, people that work at the White 

~::~House. I think its a natural instinct to want to try to 

ii1 Pardon me. go ahead. 

I?! A0 I did not - I had just been reelected to the 

f 3 1 Congress and would have been Charrman of the House Budget 

! 4 jCommrttee for that next term. so I did not seek the off& of 

r 5 1 Director of OMB But. obvrously, at the time the President 

[ 6 1 first came In. he had representahves from - as President- 

[7 lelect talked to me about economic issues that would face the 

j s 1 new admrnrstratron and asked for my recommendations as to 

[ 9 1 individuals to be rn certain key economic positions. 

IlO1 I did not recommend myself. But later on I was 

(11 lasked by Mr. Chnstopher. who headed up the reelect team - 

1121 Q That would be Warren Christopher? 

1131 A Warren Chnstooher. .~., 

i141 

Cl51 

Q Who became Secretary of State in the first one 

A Thats ’ correct. 

1161 Q He then communicated with me that the President was 

t171interested in interviewin 

t 18 1 Director of the Office of % 

me for that possible 

dp 

osition of 

Q 

anagement and Bu get. 

I191 The people who would talk to you and ask you both 

fzojabout economic issues and your recommendations, who were 

tz 11 they, if you recall? 

A I was first visited b 

I:::and just general1 asked me abou 1. 

Robert Reich who came in 

J 

Issues related to the 

r241economy. what o to on the bud et, what steps to take what 

[251 my recommendatrons were, kr ndg43fageneJeCeverviewbf 

Page 21 

f 1 Ieither see or be with the President as often as you can, 

12 1 because thats ’ one of the - I think one of the rewards of 

I 3 I workina in the White House, is to have that kind of 

ut I wanted to as Chief of Staff, assure that 

I 6 loeoole met with the President if thev had a reswnsibilitv to 

But one of the concerns that was raised with me 

i :i I when I took over Chief of Staff was the concern about 

( I 91 individuals who would walk in without any appointment and try 

f2ojto see the President. 

1211 Q And, I take it, that wasnt ’ a security concern, it 

[ 22 rwas a job efficiency concern. 

I231 

1241 

_ A Thats ’ correct. 

Q And those were raised with YOU bv the President 

i;~ihimsetfPage 24 

[ 1 leconomic issues. 

f21 

f3jwho 

And then after that, I think it was Mr. Christopher 

came by and asked - asked the same questions, but then 

t4 lasked more about personnel, who would be my recommendation 

tslfor Secretary of the Treasury, who woukl be my recommendation 

[ 6 1 for Director of OMB. who woukl be my recommendation for other 

f7jeconomrc 

go 

sitions within the administration. 

1 ii Reich? 

Anybody else other than Mr. Christopher and Mr. 

f101 A Those are the only ones I can recall. I believe I 

[ 1 I J ma 

( 12 1 ha J 

have had some phone conversations with Gene Spurling. who 

headed up some of the economic issues during the 

f13]campaign. 

Q 

I::;for interviews with anybody? 

After you heard your name floated, did you go in 

(161 A The President. The call came from Mr. Christopher 

t17lthat the President wanted to talk with me, and that - I was 

[ 18 1 asked to go to Like Rock to sit down with the President. 

[I91 And I did that and was taken to the 

fzojmansion and was interviewed by the Presiden 9 

overnors ’

1211 hour. We talked economic issues and - 

for well over an 

(221 0 One-on-one interview? 

1231 A Yes. 

Q 

i::lbefore you went in to see the President? 

And did you interview with anyone else down there 

Page 22 Page 25 

Ill 

A0 That -when s ’ cmrect. he was telling you what he wanted you to 

I:jaccomplish as Chief of Stat?? 

(41 A Thats ’ correct. 

Q By the way, those two deputies you mentioned, the 

/ 21 policy andihe per;onnel - 

I71 

I91 

2 When I first became C tef of Staff Harold lckes 

who were those peofte? 

[ :iiwas given the responsibility to handle the political 

1 II loperations, plus some policy areas, to oversee some potii 

rzorrequest - 

I211 Q Pardon me. 

I221 MR. WISENBERG: 

If:ithedoor. 

THE FOREPERSON: 

Did that happen gain? 

It almost rd. b no one opened 

t251 MR. WISENBERG: 

[II A No, not t!!tJu~ti!. 

Page 20 to Page-25 
3216 

BSA Leon Panetta, 1128198 

______~~_~ .-.. -~~~- -- ___~____ UUYW 

Page 26 

: ; rarsed IS that there was no ob.:ous tnp director on each of 

.: I the tnps that the President ha? taken prior to my becomrng 

.3 j Chref of Staff, and that some~~s it would vary, but there 

.d I was no clear leadership on a tnp. 

i’ In addition to that. people would often 

6 j trips that were not cleared in any manner, so tha P 

o on the 

oftentrmes 

i 7 ] people would accompany the President that had no partrcular 

: 3 ;policy purpose for bein on the tnp. 

:>I And so I did Lo things Number one. I wanted to 

. _ 3: make sure that whoever was t?ere. either myself as Chief of 

.., _ _ iStaff. or a Deput 

J 

Chief of SM. was recognized as the key 

:z ; trip director. An , therefore, rf there were uestions of 

; 3 I policy or personnel, that that person could %s turned to for 

i 4 j decisions. 

:I51 And, secondly, we would look at who would go on a 

: I 6 I oarticular trip and make decisions about who would accompany 

! :; i the President. 

:131 Q When you say %ve,” that would be you and your 

eputies? 

A MvcPlf and the deouties, thats ’ correct. 

r you ever became aware of in 

::s)d 

:201 Q ‘

._. __.. _.._ _._ -- ----- 

Was there anvbc& else 

ii: 1 addition to the Pres 

:zs)Chiel 

:24 )apparentlyAwas_ 

:251 

_ Trident who wasypushjng for, you to become 

f of Staff so;;at&r+r could bnng this drsciplrne that 

The Vice President is a friend that - someone i 

Page 27 Page 30 

: 11 have known, for a ion time. We were. elected,to Con ress the 

islactual 

; 2 1 same rr: In 1976. %td it was the Vce President w#o 

came to me and sad mat the President was 

{ 4 1 interes ed rn talkin with me about being Chief of Staff. 

r 51 And I told the Vice B resident at that time that I was not 

iijinterested. but he continue to push. 

Q 

ii 1 indirectly, for you. 

Anybody else who was pushing, directly or 

A You have the President and the Vice President, you 

~~~dont ’ many others. I dont ’ know. I dont ’ know. I think 

: I 1 that Mac McLarty, my predecessor, often talked t,o me - or 

:z 1 asked me for my recommendahons as to how to improve the 

.~~. : 3 I operations of the White House, and I would give him that 

: : 4 1 guidance. 

::51~ Cl What were your typical hours when you were Chief of 

i 24 i initiatedas ’ Chief of ‘ Staff. 

;251 The first staff meeting was at 7:30, and then it 

__ ----- 

Page 28 

::ojmake. 

There might be additional briefings later in the 

: i i i afternoon and sometimes receptions in the evenin 

I .; 1 was a pol&sl meeting during - as we had 

.:I lcamoaran. sometimes I wouldnl get home 

ii5jthate&nin 

;I61 r? ormally. I think around 8:30 or 980. I might be 

: :7 1 able to leave. So a normal day would run somewhere between 

: : 5 )7:00 to about 9:O0. 1O:OO in the evenin 

bo its a L4-nour JOD. 

Cl How many ttrnes would you -what do you define as I 

Page 29 

[: ;the middle;f the night, after midnight? 

I remember getting a - I mean, the first ca!l I 

i ;; got as Chief of Staff was about 2:30 in the morning, and fl 

;: : came from a Secret Service agent who told me that a plans had 

15: gone Into the White House. F Q If you can recall, how many times - I dont ’ expect 

i:; an exact number, but how man 

r 

times when you were Chef of 

(pi :Staff would you get a call from he President waking you up, 

t 31 the President personally wakingJou up? 

1c; 

111 

;121 

Aa “,o,o, many times. 

A It was a number of times. I cant ’ give you an 

113 Iestimate. I mean, I just, you know, it - it would happen a 

[ I I j number of times. 

0 Can we say less than 60? Is that - do you feel 

I:zlcomfortable with that? 

t171 A Dunn the time I was Chief of Staff? 

Q Yes. 3 mean, if we could do it like 25.60. 

~:~~understanding that youre ’ not - 

A Somewhere between 25 and SO, I guess, but. again, 

i:y!thats ’ an estimate. I donY recall you know - 

Q In a typical month - again were ’ not holding you. 

i:::We know theres ’ no way you can remember exact1 

z 

In a 

(24 Itypical month how many times would you get awa 

tz5)callfrom the President..asChief-ofStaff? 

ened by a 

111 

121 

Aa ;e;,typical month? 

I31 A 

Q 

Sometimes maybe ten, ten times. 

I41 Would that be ty 

A It varied. Imjus ’

156ibest estimate of 

P 

ical or unusual? 

- Im ’ giving you. I guess, 

t11beOy 

ou know, ;r 

ou know - and, again. sometrmes it wou !y 

I went home and went to bed at 1l:OO. 

ts111:3 - youre ’ usually exhausted in these jobs, so normally 

tslwhen I ot home, I would try to et to bed, and then perhaps 

1 ~o)soon a f! er that, I might get a ca r9 from the President. 

Q By the way, its ’ very hot in here. and Im ’ sure the 

[ii~~%~/~%rke mine&soon. 

if you wanted to take your coat. Im ’ probably 

I::iStaff? 

About how many people did you supervise as Chief of 

A Well the primary su rvision. again, was, you 

i:tiknow with the deputies but if ou oak at the key 

Wl-ritecuse crbvious~ that 

’ 

[ 18) presidential personnel iir me 

tlglwould number, I would estimate, somewhere close d 20. But 

tzo)then. obvious1 

tzl)of the White f? 

you have the responsibility to oversee all 

ouse staff, which can total a few hundred. 

Q And when you say total White House staff, you would 

i::ibe the ultimate person in control, I guess, next to the 

rz4 I President himself. 

iZ5i A Thats ’ correct. 

Page 31 

-.- 2 

I: Ithat indud: - a~?%%?%%?& people in the Old 

t3lExecutiie QfJce B!rildin~? 

Im ’ ust ‘ trying o see if 7Nhite House staff is a 

I:itemt of art. ou know, does that mean Executive office of 

r .-, 61the President? 

A Well. I think, yeah, you do have to break thii down 

!i;so mat you understand. I mean. my da 

[spvith a lirp(te$ grou of White House sta x 

-today contact was 

that had key 

;;;;;s~;brlrttes. $at was - and that was 

7 30 meeting and at the 8:15 broader sta meettn . 

u;# handy 

But then there are obviously a la I::; people under those individuals, both rn the 

e number o 

rte House as 

(14 Iwell as the Old Executive OffIce Building who ultimately you 

tls)could say as Chief of Staff I am responslbk for, but 

t16)obviousty did not deal with on a day-to-da basks. 

Iiilindusive? 

Q Okay. And that number o ? 200. ts . that meant to be 

What Im ’ asking ou about is uttiite chain of 

tl5lcommand. In other words, i! a decision has to be made to 

t20)reward. discipline, transfer the people ou have ultimate 

12 11 line authority over - you mentioned a xs ure of 200. Was it 

122 1 potentially even targe0 

1231 

t241 % 

A 

~sy&%rdude in OEB and - 

1251 I think it goes up pretty high. I cant ’ remember 

oIc--!%arr Page 26 to Page 31 
Page 32 Page 35 

[ ii the exact - I th r< the overall number I recall In terms 

I? loverall staff was you know, almost 5.000 or 6.000. I 

(3lbelleve. 

141 Q In !he White House Itself you thmk its ’ roLx$ly a 

! slcouple of hundred7 

161 A I !link thats ’ correct, 

[7! {Grand Jury Exhibtt No. LP-1 was 

Is! marked for identification.) 

191 BY MR WISENBERG: 

101 Q rve 

6 

ut in front of ou what weve ’ marked as Grand 

111 Jury Exhibit LP-i o you have &at in front of you? 

121 A Yes, I do. 

This has been given 

i17i . $ zqota pen. - ’ 

m gomg to ask you to help us determrne. 

1:89ithe best okyou\gmory. what some rooms are. Is that okay? 

to 

t201 

Q We have at kind of the center, at the bottom, the 

I::iQval Qffice. is that correct? 

1231 A Thats ’ correct. It states “Oval office.” 

i241 Q Thats ’ how I knew. And its ’ also oval-shaped. 

r.251 Thats ’ where the President conducts most of hrs 

Page 33 

[ 11 business when hes ’ in the White House? 

I$ i President 

A Thats ’ correct. The President: and this 

- its ’ probably varied throughout hrstory but 

I 4 Ithis President drd much of his work in that office. the Oval 

[5]Oftice. at his desk 

0 Now ou see the little room, or odd-shaped - 

it; almost likeAa rn;p-of r he United States up In the left come0 

[El 

191 Q 

Ilolnot a room. 

What is that room? Or what is that thing? hs ’

Ill1 A 

I121 Q 

This area here (indicating)? 

A 

Yes. Is that a room or a walkway or - 

Cl31 That actually is a walkway. It ives the 

fi4lappearance of be8 a 9 

I 15)that appears to the “ik 

room, but if you look a that hallway 

ft of what you indicated, this is 

ti6)really a continual walkway that goes through here 

I 17)(indicating 

t1s1 4 

and - Im ’ not quite sure how this - oh, okay. 

eah. 

tIs)(indicatin 

the walkway would go like this through here 

rzolthe recep 9 

). and then this would actualty be the entrance to 

Ion area and to the Oval Qffice. 

I211 Q Okay. .You have drawn with a blue pen that weLe 

;;;;zgfnjot&n arrow teadrng from - to the left of what Ive 

as the shape on our map that likes kind of like 

tz4)a - 

I251 A Crossword puzzle. 

Page 34 

Ill Q Yeah, perverted map of the U.S., you know. with a 

121unicom on the top. 

I31 A ‘ 

I41 Q 

151 A 

%%tualty - its ’ about - 

Its ’ about - if you took at the Oval office. Ys 

-t6)aboutat11:00.ifyouwereiookingatadock,andat(ii:OO) 

1711s that symbol, and that really - thus kind of distorts it, 

I a )&cause I think those are the doors that open up in each - 

[ s)nto these different areas, or 

c? 

ives the impression that its ’

[ lojan enclosure. Its ’ not an en osure, its ’ basicalty a 

I I 1 tconbnuous walkway that goes through there, and those doors 

tt2)are normall left open. 

1131 cr Pardon me just a moment. 

I141 I want to make sure I understood. The file arrow 

I istthat weve ’ called a map that looks like - somebody said it 

I ,__, I 6 I looks .~ like - a --..- bird - 

I171 A JUROR: It does look like a bird. 

(181 BY MR. WISENBERG: 

il9i 0 - wi+.. its win 

rzolwalkway area. Its ’ just that t 8 

s open, that is actually also a 

ere are doors - its ’

121 lendosed on all these sides by doors. 

I221 A And those doors are normally open. I rarety saw 

1~31those doors closed 

I?41 Q And are those like doors that you could~ust push 

rz51open. or are they like doors with a knob that you open. 

A My recollection 5 that theyre ’ doors with a knob 

.f :that you can close, normal doers 

: Q 

: clear ‘

All right.. Lets ’ Mme these so that the records ’

Id ’ like you to mark the iong walkway to the left of 

5 .the - what Ill ’ call the eagle 

: that ‘ as Walkway 1. You wou 

?t now, if ou could mark 

: f: long walkway. 

?I agree w it!7 me that thats ’ a 

A This is a long walkway. 

i‘ 

r. - .one. were ’

Q Okay. That wook! be this walkway here, this long 

.-- oing to mark as Wa!kwa 1. /.. _--_ he witness marked the dy 

MR. WISENBERG: 

ocument.) 

;.-/ *-. 

113: Q And the area endosed -that youve ’ identified as 

I: 4 : enclosed by doors that weve ’ called the eagle and the map, 

: : 5 : Id ’ like you to mark that as Walkway 2. 

!16j 

[:;I 

&!-$hw$E;, document.) 

11e; Q Now, the Walkway 2 area, in turn 

t~swell. it goes into the Rooseveft Room, it goes into *9 

oes into - 

he Oval 

120 ~Office. or it gets you access to the Roosevett Room and 

r 2: I access to the Oval Office: is that correct? 

A Thats ’ correct 

131 Q Are those - 

I24! _ 

I251 

(11 

I21 

137 

Page 36 

$ $a;~ ‘ right. 

A The h oosevelt Room door is dosed and the door 

i4 jthe Oval Qffice is closed. 

151 Q 

[ 6 1 or just closed? 

Do you know whether or not theyre ’ typically ldcked 

A My recoltection is that the door to the Roosevett 

ii j Room is normally not locked so that if you wanted to access 

(9 lthe Roosevelt Room, you 

(1 o 1 in. 

could .ust turn the handle and walk 

But that access to the Oval &tics is locked. 

Ilil Q Now, theres ’ atso -Walkway 2 gives you direct 

I 12 1 access to Walkway 1, correct? 

il31 A Thats ’ right. 

(14! Q And then it goes up to a room thats ’ not labeled, 

I I 5 1 or perhaps to another walkway thats ’ not labeled. What is 

[lhjthat area, if you know? 

il71 A 

I I B J 

)! 

oure ’

That area there, which is, again, located - if 

in Walkway 2. it would be the upper 

[ 191 .lke a door or - Im ’ not quite sure how to de Thne ’ this. -.rt looks But 

I 2 o 1 rt would be that - on the right-hand side of that symbol 

tzllthat we described - 

1221 Q Walkwa 2. 

1231 A -ofWa x, ay 2 That leads to an area that is 

124 )usualty and can be used as a waiting area for those who 

[ 25 1 erther are visiting with the President. or if Ts a cabinet 

Page 37 

(11 mop meeting, sometimes stat? mt&mwthet~foremey 

(2 1go into the cabinet room. There are some chaits in that room 

t 3)for seating. 

I41 And it can also be used as a continual walkway that 

I 5 1 leads to - back to the lobby of the White House, or if you 

I 6 lconbnue to follow that, will ultmety lead to where the 

[7]PreSS is located. 

187 Q All riaht. Why dont ’ we designate that as Waiting 

[3]kea l? 

I101 

I111 

ghe witness marked the document.) - 

R WlSENBERG: Does everybody know where we 

11.71 A JUROR: Almost. Yes, okay. 

1131 BY MR. WISENBERG: 

Q Now 

i::;lobby. Thats ’ mark l&K 

ou ment&ed the lobby. We can see the 

r1s1Area 1 

I take it the area between Waiting 

- weve ’ called Waiting Area 1 and the lobby is yet 

I 17 I another walkwav. 

I181 A Thats ’ correct. 

I191 Q All ht. Lets ’ aLtthat.kI&lkway.3. 

t201 MR. WtS?NBERG: We all know where that is? 

1211 THE WITNESS: Thats ’ the area thats ’ just north of 

122 lthe Roosevelt Room. Theres ’ a walkway there. That woufd 

[23]be -what are we oin to describe that as? 

r241 BY MR.%&NBERG: 

i25i Q Walkway 3. 

Page 32 to Page 37 _ OlCStarr 

- 
3218 

Leon Panetta, Ii28198 

Page 38 

The area next to Waiting Area No. 0 is an area that 

:::!I would call another walkway. You1 notice stairs there to 

[ 24 ] the fig& a Se!& ‘ of tines t&e. ws a &Imn and 

tzstthat s mvell leads downstarn to tha lower level of the 

Page 39 

e witness marked the documanL 

And, I take it, th oor leading from WalkwayOto 

i ilt~~~~~~~~~~t~~~. t think 

t 16 1 Ive ’ never seen that door used. 

0 Now, the ofticar that you mentioned - or Secret 

~::~Servica parson - 

A Actual 

~:~~press is brought into 3[kcabin~.-fofaphoto 

lapel ze. Thatdoorisusedwhenthe 

t211”pgprt unity . wrth whoever is visiing the Pnxrdent tn the 

122~~3 met roam. Normally the press B bmugM in through that 

__-- -_ .-___-__ 

111 Q 

I~lCOrlM? 

Thats ’ the door from Walkway~o the cabinet mom. 

131 A That% right 

Q You mentinneda 

Illof some kind. _ personoranm 

I61 A Thats ’ correct. 

Q Isthatinthatfirstliileftboxupandtothe 

I:;right of Walkwa l ?, 

l:t~littleboxthathas 

A &ts~hLLs~outu~mW~.w%&into that 

tllttightpfwherethat isbcatedfwmaltyi;adeskthathas 

f12la poke ofticar located at 

iiei 0 AndcanIaskyoutotetluswhenyourofticettsjwhere the Chief of Staffs OfFice was? 

Page 41 

Its ’ not actually designated on t& map 

A Tharscort-ect. 

Would this little thing mean anythii to you. this 

Page 42 

I&t recnlkction is 

A “fi~~p;;$~~~~$a$.“” 

r3wper rigM-hand amsr ofwhatiscalledtheovalQftke 

141comp~x. 

0 AltNht. Sothepresidenbaldiningroomhin 

$re oval fmice Camplex? 

I71 A Tharscorred 

ii;within it. +?ie dZ$%cnn is within tha Qval Off& 

necessarily the entire thing but its ’

r101ccwJkx. 

A Thereis-inthatrodmcaltedtheQvalQffrca 

Page 43 

OlC-.Sta~ Page 38 to Page 43 
3219 

__. Leon Panetta. 1128/98 Iu&xl*I 

Page 44 

: I Q All n 

I! 

ht. 

: 2 j think IS a d?rway 1, at 

Then to the nght of that is what you 

leads into the pantry. 

:?j That s correct 

4: ‘ Q Okay. Why dont ’ we put a “PD” for pantry door? 

5 ‘ !And il you need to an arrow there from somewhere else, you 

iican 

1 

Ii 

he witness marked the document.) 

R WISENBERG: “F” IS the top of the Oval Oftice 

;jComplex room, the top white is the ftreplace. and to the 

: : : j right IS “PD” for antry door. .1.1 ,_a, A JU X OR: 

:,7, < _- > BY MR. WlSE%%tG: 

.3‘ ’ Q And the dining room is within the Oval Offtce - 

1: c i whats ’ been designated as the Oval Oflice Complex. 

[:5! Can you tell us who is in - youve ’ mentioned in 

! : 5: Waiting Area 1 there are chairs there. Is there typically a 

c :T 1 secretary if an kind in Warbng Area l? 

[I91 1: o. there s not. 

0 

iii;back lo the Oval 

CadffyouJell us w\; the area is - ny heading us 

ice t&elf. can ou tell us -there s at 

f 2: 1 the very top of the Oval Office a II le area that looks - 

1 :I 1 Its ’ shaped like the fireplace in the dining room Oval office 

ri3lComplex. Is that a fireplace? 

1241 A Thats ’ a fireplace. 

1251 Q Okay. And lets ’ just mark that with an “F,” too. 

Page 45 

!?I 

kc MR. WISENBERG: 

he witness marked the document.) 

[?I 

i:lon the up 

Q Then there is a parently a doorway leadin at 1:00 

f 5 1 Office; I phat ” correct? 

r right. a doorway P o another room out of the 8val 

!61 A Yes. That is normally the entrance that is used 

; 7 1 when goin 

i ilasking 

8 

in and out to see the President. 

Is that typically - and these questions that Im ’

: 3 j open, 

ou about the doors are they typically dosed or 

t x ats ’ based on your betvice - your answer as when you 

i: 1 were Chief of Staff? 

121 A When I was Chief of Staff. Im ’ basing it on my 

: 3 : experience as Chief of Staff. 

:41 Q And was that generally kept closed - 

I151 

116! or open? Closed? 

And what is the room or walkway that that goes 

Page 46 

ats ’ coirre,ct. 

rou could olease mark that for us as Reception 

11clArea 1. 

I151 

I: f i break. Before you all leave I need to mention one thing to 

t 18 1 ou. 

[ 141 g

but Im ’ gomg to ask, wih the permission of the 

oreman. ma the witness be excused? 

[ZO! THE FOREPERSON: Yes. 

1211 MR. WISENBERG: Well ’ come get you in about ten 

(22 1 minutes. 

113: 

Y 

ltness excused. Witness recalled.) 

HE FOREPERSON: 

li:iyou that youre ’ still under oath. 

Mr. Panetta, Id ’ like to remind 

---__, 

Page 47 

ii: THE WITNESS: All right 

171 MR. WISENBERG: Let the record reflect that Mr. 

i: ( Panetta has reentered the grand jury room and that we have a 

: 4 ! quorum. 

BY MR. WISENBERG: 

0 

i :ii map and you go u 

And then if you walk through that doorway on the 

[ 14 1 designated there. P 

and - it looks like a wall area is being 

f you go beyond that wall and take a 

[ 15 1 right, you have drawn a rectangle, which is Betty Curries ’

[ I 6 ] desk; IS that correct? 

[I71 A Thats ’ correct. 

[I81 Q 

$ 

All right. And if you could - 

[I91 

17rl1 

L-“, 

y;oufant me to mark that VC”? 

I211 

[221 

~Mi$&g&ge~dt~ document.) 

I::;Area 1. 

Q And where weve ’ marked the general area, Reception 

I251 A ThatSwtTeCt. ’

Page 48 

r11 Q All ri ht. 

[21 MR. WISl!NBERG: YOU all need to see where that desk 

[ 3 1 is located? 

I41 A JUROR: We saw it. 

[51 MR. WISENBERG: You saw mat? Okay. 

[61 BY MR. WISENBERG: 

f71 0 Now, who else is in that reception area, typicaliy, 

18 1 when you were Chief of Staff besides Ms. Cunie? 

A Normally the Only people that are allowed in that 

I:,; ‘ area are those that are individuals that are either 

I 111 deliverin 

I 12 1 Hemrei .ci! 

something. obviously, to Betty Cumie or to Nancy 

, whos ’ also located in that area. I assume well ’

[13lget to that, but - 

[I41 Q Yes. 

A And then it would be no-1 me staff or 

I : 2; individuals that are about to meet with the 3 resident. . It is 

[ 17 1 normall not an area where peo le are allowed to simply stay 

1 valor wan J er. Its ’ an area that IS, f!i r a better term. is 

[ 19 ] normally the preliminary step to going in to meet with the 

[ 20 1 President. 

1211 

r221 

0 Okay. No loitering. 

.~.. A That s correct. 

Q 

i::)addition to Be 

Now, who else is regularly stationed there in 

1251 A %&r?;u - again, exiting that door at 1:OO 

Page 49 

[ 11 off the Oval Dffice,if 

(2 1 left-hand side a smal p” 

crproceedup, youd ’ see-atrmgthe 

area that has an access off of 

r3lReception Area 1. Located in that area is Nancy Hemreich. 

I:idoorway? 

Q Okay. Youre ’ talking about what looks like a 

A 

1761 indentation off of Rece 

Thats ’ correct. Again its ’ a little V-shaped 

tion Area No: 1. 

181 Q Is it, in P act, a doorway? 

191 A That really 6 a doorway. 

[lOI Q 

A 

Okay. And is that typically.ke t open or dosed? 

Normally it was open, althoug R there were often 

I::; times when Nancy, in order to do her work. would keep that 

rl3lclosed. 

I141 0 Now, Nancy is exact1 where? 

A Nancy -the desk for 5J 

i : 2 : approximatety in the middle of that area. 

ancy Hemreich is locat+ 

I171 Q The V-shaped area? 

I181 A This (indicating). 

I191 Q LetmeloakuJl 

I201 A Thig prea herep! Dhroluy. 

Q 

$:1] basically 

Sotisinthea ual-theroomthatisonT 

ht on top of the Oval Office. 

Yeah. If you look north of the Oval Qffice. on the 

:::; other side of the fireplace there is a little area there 

[zs,That is a very small area.but ‘ it does contain a deskfor ’

Page 44 to Page 49 OlC-stan 
CISA 

Page 50 

(11 Nancy Hemrelch. who is the other atde to the President. 

I:! 

6!f MR. WISENBERG: 

he wrtness marked the document.) 

131 

Id! Q 

I51 A 

;;ti;.uve ’ drawn a - 

I51 Q A desk for her about in the middle, or the middle 

i~jand maybeA-- 

[B! Approximately in the mlddle of that room. 

[9i cl In the middle of that room would be - and you put 

[ 10 1 an “NH”? Is that how you - 

ill1 A Thats ’ correct. 

l12! Q Hernreich is how you pronounce it? 

113i A Thats ’ correct. 

Q And what is that - is there a name for that room 

I::;she*s in? fA that considered her office? 

I161 It was ahva s known as Nancys ’ office. 

Q Okay. An dy that doorway is usually open, but she 

i :i i woukl close it if she needed to do work. 

1191 A Thats ’ correct. 

0 All ri 

i:yidirect access from 8 

ht. And it doesnt ’ look like theres ’ any 

t at office to the Oval Office, correct? 

I221 A There is not. 

Q All ri ht. So, again, in, the reception area 

I::;itsetf other than Be r251man;led or unmann$ $;$$s desk. Is there any other 

3220 

Leon Panetta, 1128199 Xuu(9) 

.__ 

Page 53 

i I! number were ’ on: Do we have a walkway here going frm - 

[ 1 iwould you call thrs a walkway. pr a short walkway that goes 

:x!from Rece tion Area 1 to Waltlng Area l? 

141 II Thats ’ correct. Its ’ a very short walkway. 

li: 0 All rioht No door7 

Page 51 

III A No, there is not. 

Q All right. And its ’ typically people makin 

!:ldeliveties or staff members about to meet the Presiden P. ; IS 

ii jthat wrrez? 

191 Rioht. or sometimes visitors who are aoina in to 

Page 52 Page 55 

111 A Thats ’ ri ht. 

Q It would %e people who were basicall 

I G /stature and knew the White House well enough wou 7 d feel 

had enough 

[I 1 comfortable going in there. 

I51 A Thats ’ correct. 

Q All 

It i Chief of Staff to tigh “9 

ht. Was it one of our accom lishments as 

en 

18 1 Reception Area 1 - 

up that area - L ts ’ start WI .P h 

[911? 

as to who could get into Reception Area 

A Thats ’ correct. Normally - a ain, for example, 

I :iifor staff going in to brief the President, on 

(12 lwho were going to 

? 

,g ?hose staff 

o in to brief the Presl ent were normally 

113 lallowed intp Regp ion Area 1. 

111 BY MR. WISENBERG: 

I21 Q And then I think 

Of# 

ouve ’ testified that tk door at 

13 111 :OO. ieadin from the Oval ce 

[I Idosed; is tha 9 correct? 

to Walkway 2 is typiiliy 

151 A Thats ’ wnect. 

I61 Q A?d if you could ut a “C” there. 

171 

I81 

~pMgm$&rna&~~e document.) 

c:Z;also? 

Q Is that the one you told us is typicatfy locked 

_ 

1111 A Thats ’ correct. 

Q Youve ’ mentioned that the door that 

~::~outside walkway is qpicall closed. so Id ’ ask you 

ipOestothe 

114 Ican M a little tiny “C into t at. 

you 

1151 

1161 

pMpw$&&nax!&dt~ document.) 

Q And Im ’ just goin to do right now ones that weve. ’

t:iitalked about. Youve ’ mention ec? Jhat the door from Reception 

[ls]Area 1 to the_qbinet room is typically closed, so 111 ’ ask. 

iipiyou to “~~vjt%~gt?dt~ document.) 

Q 

[::iarea to Waitin 

Youve ’ mentioned that the door from the reception 

rzslto put a zero t 8 

Area No. 1 is typically open. 111 ’ ask ou 

ere. We note your testimony that on Le L 

I141 

f 

I:zjaccumulatin 

t?%t particularly like a lot of staff 

;;;;the Pres&Qn SQ 

in that.area because thats ’ very close to where 

s;wc&T.nngi 

ow about Waiting Area l? Was it one of 

(~slyour accomplishments, to also tighten up even people who got 

l_7ol Into Waitin Area No. l? 

1211. w Normally ople were not allowed to 

[22 1 ust sim 

Thats ’ right. 

( c 

ly wait around in that area. p” hat was either for 

[231 hose w o were about to 

[ 2 4 1 or about to go into a 

o into a meeting with the President 

mee P Ing In the cabinet room. 

[251 Q This is just a - Im ’ trying to see what walkway 

t-, 

i6! & The&no door. 

j l i correct? 

Q Until you get to Waiting Area No. 1; is that 

A Thats ’ right. When you get to Waitin 

I ii 1 as it shows there, there is a door, a large door, that % 

Area No. 1, 

ads 

i i 1~ to the cabinet room, and then there IS obviously the door 

: 1: 1 that leads to the Oval Office 

There is also a door that leads to the outside 

I :: i walkway that is located - as you go down that small 

r:~;tzz:;:~~ 

it is located directly ahead. So if youre ’

tty Curries ’ desk, and you go north a little bit 

117 1 to that dark area, to the right of the door to the cabinet 

11s 1 room, there is a door to the right of there that leads to the 

[ 1 glwalkway, the colonnade walkway. 

I201 Q 

(211 A 

Okay. Would that be right there (indicating)? 

That s correct. 

Q Okay. That would be this little doorway, this 

I:: i little area right here (indicating), right before 

[24 lthe cabinet room that juts out to the right oft K 

ou get to 

e 

[zslarea. Thats ’ a doorwaytotheoutside. 

reception 

. 

Page 54 

III A Thats ’ correct. 

[21 

131 

[II 

151 

Q 

It;cabinet room, is that typically closed or open. 

Okay. The door from the reception area to the 

I81 A 

Q 

To the cabinet room is normally closed. 

r:i;Area 1. isFat 

The door from Reception Area 1 leading into Waiting 

VI! 

ically closed or open? 

ats ’ normall open. There were times on the 

I :: 1 weekend when that door wou 7 d be closed, so that the tourists 

[131who normally can go t~ughtheWestWmgwoutdw&~eable 

c 14 1 to walk into he reception area. 

I:zi 

Q Okay. We havent ’ been doin 

fi 

oing to ask you to do it for the record. and t a. 

something, and Im ’

at IS. we 

[ 17 1 avent ’ been markin 

118 1 closed. If we could 2 

which doors are typically open or 

o that. 

OlCStarr Page 50 to Page 55 
3221 

BsA Leon Panetta, 1128198 

-___ -.-.__ 

Page 56 

! I iweekends tis sometimes oosed. 

(21 rThe witness marked the document.) 

r3: BY MR. WISENBERG: 

Q You have rnentroned that the door leadin 

I: i Wakway No. 2 to the Rooseveit Room is typically close % 

from 

16: A Thats ’ corrti 

173 Q 111 ’ ask you to put a “C* there. 

181 

[91 

~T&vvitn;~Er4B~ed&e document.) 

Q Youve ’ menhoned that the door from the Oval Qftice 

:~~Ccmplex. which contams the dining room, that the door from 

. 12 .~. lthat to Walkwav t is t-mcal~ dosed. 

1131 A Yes. _. _ 

Q Ill ’ ask you to put a “C” there. I think thats ’

i ::ithe one you testified theres ’ a security lock? 

1161 A Thats ’ aanect. 

ii7i 

1181 

Cl91 

~~~~~&a&ed&e document.) 

Q Youve ’ mentioned that the door from Waiting Area 

I:!fNo 1 to Watkway 3 is typica& open, Waiting Area 1 to 

.--, 122rWakwav 3: is that correct? 

I231 

r241 

1251 

- A Thats ’ correct. 

Q Ill ’ ask you to put an 0” ‘ there. 

(The witness marked the document.) 

Page 87 

BY MR. WISENBERG: 

And that the door from Walkway 3 going down into 

Cl41 Q All right. 

A 

i : 2 i into the Roosevelt Room. 

Q 

I shouM aW&n.it;~~$~~;~;~y No. 1 

Okay, thank you. We havent ’ marked that yet. 

(:i;Thats ’ Walkway No. 1 up into the Roosevelt Room. 

r191 

I201 

~~~~~~~~~~~~~ d@==nt.) 

Q And I think 

I:: iwafkway No. 4 into the 

ou mentioned that the door from 

ca t? 

tt3jthe cabinet room - 

met mom. thats ’ the top teft of 

1241 

1251 Aa Yes. - that door is nomialty dosed. 

--- --- 

Page 58 

A Thats ’ conect The upper door - 

Q 

A 

Upper left door. 

That% correct And normath+ the tower door is 

. --, 

I141 

II51 

I161 

1171 

A Yes. 

- there is a doorway leading into something. 

i Thats ’ correct 

Q Lets start with. what is that lea&to into? 

iisi 

1191 

1201 

1211 

A 

QThat leads into a very small haltwziy. 

Al! right. Well ’ call that Hall 1. 

~TM”~;s”E document.) 

i22i Q Andt~n-~~atd~r~p~~~or~n, 

t z 3 1 the door from the Oval Office to Hall 1, 

A 

you know? 

1241 That would be normally dosed. 

I251 Q All right. Would you put a “C” there? 

Page 59 

111 

BY MR. WISENBERG: 

The witness marked the document.) 

131 

j:ldownward 

Q Hall 1, from there there appears to be a door going_ 

tnto another room. isi A 

lb! Q %$ is that room? 

A That room I would, for lack of a better word, call 

1; i the Presidents ’ study. 

A 

i iilmark rt “Studv.” 

Okay. Well ’ call that “Study.” Ill ’ ask you to 

1 

(111 

I121 

~~~~~~~~~~~~ document.) 

; ;;lor closed?Q Is the door from Hall 1 to the study typically open 

.--. 

Page SO 

111 this - whats ’ this tile area just due north of Hall l? 

A 

I:iinto Hall 1, that first area to the rig t IS a bathroom. 

The first area - asp go from the Oval Qffice 

j41 Q 

[SjCorrect? 

Okay. So thats ’ a doorway to the bathroom, 

I61 A Thats ’ right. 

[71 Q Is that typically open or closed? 

I81 A Closed. 

$fbath? 

Q Okay. Do you know if thats ’ a full bath, haif1111 A Its ’ real a half-bath. 

1121 Q Okav. l? II ask vou to out “HB” in there for halfil3jbath. 

I141 

IlSl 

Cl Then is there another room - the other area - is 

i :7”; there anot?r a,rea that a doorway enters into off of Hall l? 

1181 

Q 

r:$e here - 

T&es ’ an area thats ’ marked in white. if you can 

rzli .--. A Yeah. 

1221 

2 

- due north. 

Im ’ not familiar with that area unless its ’

~~~~~spa~oft~~~a~a. Buti-yaukna& thatmaybe 

rzslwhere theyve ’ outlined the pantry, but I dont’remember ’ a 

rlldoor 

121 

131 

i4i 

151 

161 

171 

fB1 

kadin 

c? 

A 

AQ 

! 

Page 61 

into+lalhxaytfremtlmtarea. 

As t&t pantry. 

Oka . Youve ’ idenb8ed already VW - 

As the pantry door, rtgM? 

mars correct. 

Is it conceivable that that leads into - 

ttctcM - there could be - 

area where the mess stewards keep 

ou dont ’ recall ihat th&es ’ actually a 

Is it fair to say you can? era 

i ::l pantry? Youve ’ placed the pantry door 

3 

place the 

y;y” the Ffilty hhere? 

ut you cant ’ exactly 

thank thats ‘ fair to say. I never really spent 

f191ttme in.the pantry itsett, so its ’ a lii hardfor mab 

;;;;define b geography 

But asad on your know&&a, is it fair to say that 

t22jthe - if you know, that theres ’ no door from the pantry into 

1231Walkway 1. if you know7 

A 

i::!into the pantry. 

No, no, there is a door that leads from Walkway 1 : 

-_- ___~_ 

Page 56 % Paie 61 OlC-Sz% 
3222 

WA Leon Panetta. 1126198 

Page 62 

Q Okay. And theres ’ also a door from the pantry to 

I: I]the Oval Offce Complex in&din the dinrng room. That 

[ 3 Iwould be where youve ’ marked -F&m* 

[ 4 1 the dining room. 

That appears to go into 

I51 A Thats ’ riaht. 

i61 Q Okay. - 

[71 A That - the steward has - theres ’ not only an 

[ 8 lentrance into the pantry from Walkway 1. there is also an 

[glentrance into the Oval Office -whats ’ des nated now as the 

1 loldining room, theres ’ also an entrance into t X3 re. 

I111 Q Oval Oftice Complex. 

fl21 A Thats ’ correct. 

1131 Q Right. 

A 

I::;that dining 

So you can adually walk through the pantry into 

room. 

1161 Cl Okav. from Walkwav 1 - or out into Walkwav 1. 

A That% right. _ 

-. 

Q Do I need to repeat that? Or out into Walkway 1, 

Page 63 Page 66 

[ 1 ldining room into the pantry is typicall dosed? 

I21 A Thats ’ normally dos eJ . 

Q All right. Since I dont ’ think - weve ’ already 

i:iput “PD” there, you might want to put a “C just ht 

[ 5 l underneath the pantry door somewhere. a Me -z!- 

t61 

I71 

gpgpg~&g$g~d-~nt) 

Q 

!z!Walkwav 1 riaht on too cd where iou miaht exit from the 

And then I guess a little C‘ ’ scmewhere in 

And Walkway 2 to Walkway 1, is that typiilfy open 

isi A 0 n. 

Q OEy. I think you answered that before we were 

iii writing it “~~tng;maxtJ$w document.) 

0 

I:flthe middle ri h&hand portion of the Oval &fide. Is that a 

Now lets ’ take a look at 360 in the Oval Office. 

I 12 I doorway tea In 

1131 A” ?,a&_. 

out Into the walkway? 

[I41 Q Is that typically kept dosed or open? 

I151 A Thats ’ typical 

1161 Q Is that typical ): ‘

dosed. 

bdced. if you know? 

.-, 

rlolpantry. * - ’ 

. _ 

A Now, normally, if the stewards are there that 

I :: ito the pantry will be open, going from Walkway 1 into that 

Il3larea. 

I141 Q 

[lslsteward. 

Okay. Its ’ typically closed unless theres ’ a 

I161 

1171 Aa %%? %&. is il possible - and we wont ’

door 

i 1 a j speculate on this much more - but since youre ’ not sure what 

[ 19 1 the blank area is to the north of Halhva 

[2o]wnfident that theres ’ a pant 

1. are you fairty 

[ 2 11 as oppos$ to \Ct;kwa y 27 %scause~topkskkedoor tha goes Into Walkway 1 

t221 

t231 0 Youare. 

1241 A Yes. 

I.251 Q Okay, all right. tf you bok at wr map here, it 

Page 64 

t 1) tanks as if Walkway 2 oes into this odd-shaped - has a door 

[I 1 Into this odd-shaped w 4. 4te area that we cant ’ identify that 

t31you thank might be another pantry area. 

Are you aware of a door frdm Walkway 2 into this 

I : i unidentiftt area? 

A 

I:jother. so - 

Im ’ aware of one door into the pantry area, and no 

,QI 0 Okav so - 

x Wt%%%r thats ’ located. I mean, I think - 

Q All right. 

A Mv recollection was that that door was located just 

sur 

Page 65 

--..I 

Ill 

[Zl 

131 

Q 

A 

Q 

Oh, h sorry. 

Oka I was asking about Walkway 2, thpug? 

You identhied four doors leading out of Walmv 2. 

i 4 1 the eagle. 

[51 A Right. 

Q But then youve ’ got what could be a little - it 

176imight not be a door, but youve ’ got this odd-shaped ama - 

181 A 

191 Q 

Right here (tndicatrng). Is that riiht? 

Yes. Do you recall such a door. 

LlOl A As I stated, it may be that theyre ’ identifying 

[ 111 what is the entrance to the pantry as being - 

1121 Q In Walkwa 2. 

I131 A Thats ’ righ r 

Cl41 0 

[151 

But uniqs it is, you dont ’ remember. 

1161 A Q Thatsr?ht. Okay. ou dont ’ remember that dcor there 00 our 

1241 _ _ A That is typically c-pen. 

I251 Q Ill ’ askyotrtoput an o‘”there. 

Page 67 

(11 A Thathwrrut. 

Q 

I:~Clinton_used it a life more than other presdents; is that 

And I believe you said that you thought Pras&nt 

[4]correct? 

A 

i : ; understanding of 

That was - that was my - at least my 

hito 

t7tNixon rarety used it an II 

although. for exam te, President 

had his main office owted in the 

ts)Otd Executrve Oftice Buitdi 

P 

. So there were other 

rs]presidentsthatkindofva~astotheirusadfit. Buthe 

t1o~argetyusadthedeskintbeDvalOfFrcaforhiswark. 

Q You said he atso sometimes wOutd do work in tha 

i::idining mom on that dining room tabte 

A Yes. For example if there was an avent scheduted 

I::ifor the Oval Office, where he woub make an announcement in 

rls]theOvalOfficeorgreetavisitingdignitaryoravbiting 

[ 16 I head of state in the Vat Dffice, then the Oval Dftica would 

1171bete:upforthepressforthateverrt Andso,therefore, 

I 18 ] them were a bt of cameras and wires that had to go through 

t1stthe Oval Mice. 

And so what we woutd then do is adjourn to what is 

i:iides. nated on this map as the Dval office Ccrmptax to brief 

tz]the 8 resdent . for any particular event he might have to do in 

t23)the Oval Qfhce. 

.Q 

!::iyouve ’ designed as his study? 

Okay. Would the President ever do work in w 

- 

OlCStarr Page 62 to Page 67 

- 
3223 

ESA Leon Panetta, 1128198 

-- ___~ 

Page 68 

t1; A 

[z~lts ’ not 

I never saw him use the study for that purpose. 

to say that he doesnt, ’ but I never saw him use the 

: 3 ; study for thi at pu ose. 

14; Q ! 

I 5 1 studv for? 

ATright. What, to your knowledge, did he use the 

Q Now letstakealookatlll. ’ Whoorwhatjsto 

1 i; the right of 111, 11 i being your office, the Chief of Staffs ’

r310ffice. 

A Yes. If ou can look at Room 111 there is a dooi 

I: 1 located at approximate r y 3:O0. a little higher. That door 

[ 6 Iwent into what I would call a recepbon area for m setf. as 

[ 7 1 Chief of Staff, and the Deputy Chief of Staff, Mr. ty ekes. who 

19 1 had Room 108. So there were several secretarial desks 

[ 9 1 located in that o n space there that is located between Room 

r101111 and Room p08. ” 

x-A----, .-.- 

A The study really has a lot of mementoes from - 

I: i that are very close to the Presrdent both from his time as 

19 1 governor in Arkansas as well as president. and there are 

[ 91 hotographs on the walls, and there are books there that I 

[ 13 liink, you know, he feels ver close to. So that he 

[ 1 I 1 enerally. I think, would use he study for resttng and for 

112 1 tnd of gathenn 

And t z 

his thoughts. 

en - for example, if he had to change - if 

I :: 1 he had to change his shirt or hrs suit because he was going 

[ 15 1 to an event or - for example, when he ve addresses from 

116 1 the Oval Qffice and he would have to cz 

ti7)he would than e in that study. 

nge for that address, 

[I91 a% 

I 19 I Relaxation? 

ou mentioned resting, regathering, changing. 

izoi A Yes. 

(211 Q Anything else? 

A If he was speakin 

I:$;from staff, he would go into the s 9 udy and use the phone in 

to SOmeOne and wanted privacy 

[24)that area. 

(251 0 What else? 

Page 71 

xMAxrrq 

illi A I dont ’ believe we have a Reception Area 2 yet, so 

[ 12 1 lets ’ call this Reception Area 2. 

[I31 he witness marked the document.) 

1141 II. R WISENBERG: 

I151 JURORS: Yes. 

Everybody know where we are? 

[I61 BY MR. WtSENBERG: 

124 Iroom? 

Thank you. Then you said 10s is Harold Ickes’ 

[251 - A Thats ’ right. 

Page 69 

111 A Thats ’ about all I can recall. 

Q 

I: i the staff, okay. 

So speaking on the phone and wanting privacy from 

So thats ’ all you can remember to your personal 

/ :; knowtedae? 

I61 - A Thats ’ correct. 

Q What about from an hrng you might have heard from 

[i; others that the study was used fo ,y” 

[91 A I think if the President was taking a nap, he would 

Ill Q Al,l right. If you could just put under 108 “HI.” 

I21 

131 

gTM;rtn&ss, document.) 

Q And if you could put under 111, your office, COS ‘

iiifor Chif o&t~@$;;a&~G~ document_) 

. . 

0 Is there even-a doorway from Reception Area 2 to 

I:{ 108. or is that just sim 

1101 A 

2 

No, tha P 

ly an open area? 

IS a door. Theres ’ a door there. 

1111 

I121 t?%Y show it here. but there is a door there. 

r 10 1 use the study for that purpose. 

1111 .~-. 0 But vou never saw him naooina in there? 

I121 A No, f really didnt. ’ ’ ’ - 

Q Well, what else? Again, based on - were ’ now into 

i :: 1 the area of not what you saw, but what you heard while you 

1151were Chief of Staff. 

il6i A It was - as I said, it was,. I think, all of the 

[ 17 I things that I mentioned. It was really - rt was real1 

118 1 area that was kind of his getaway from the - I thin f! 

the 

the 

I 19Ioressures of the office, if YOU wanted to find some peace. 

Page 72 

rl3jand that door is normally dosed. 

[I41 Q All ht. Now, thedoor- thatsclosed. ’

Now the r-t% oar teadrng from Reception Area 2 - 

I iZ ; first of all woulcr you still call the area to the immediate 

I 17 1 north of Reception Area 2 Walkway 17 

I181 A Thats ’ correct. 

izojlhat ‘ was eneralty what funderstood. 

I:: t here 

8 

(indicatin 

Thts area general area weve ’ been talking about in 

[23)-first of all Ie a *. 

) what would you consider if you had to take 

sjust take a group of rooms and 

124 1 hallwa s. What woukl you consider the most private - and 

125.1 Im ’ no iy talktng about one room here, Im ’ talking about a 

.~~. 

(191 Q All right. I mean, I notice, for instance, that 

[ 20 1 theres ’ a little openin between the area due north of 

tzl)Reception Area 2 ad . 

122 11. 

krnd of what weve ’ designed as Walkway 

But youd ’ still consider it all part of the same walkwa 

A Yes. That walkway kind ofwatks throug 

i::;then takes a right turn down to Room 115. 

K? there and 

I251 Q Okay. Theres ’ no door in the area Im ’ talking 

Page 70 

r I I general area that you, as Chief of Staff, made sure - you 

12 1 considered the most kind of area you wanted to maintain the 

[ 3 1 feast access and ou wanted the most privacy in terms of a 

e Oval office area, what would you 

tljabout,thatkttte121 A 

0 

I dont ’ remember any door tt~?re, no. 

Oka . 

J4 

So were ’ stitl talking about the area due 

I : i north of Rrpt$arsrea. Wafkway 1, correct? 

151 

Q 

~76~typically kept o 

And the door from Walkway 1 to Reception Area 2 is 

n or dosed? 

I91 A %at woutd normally be open during the business 

i? 

Page 73 

.i6j A I think the most important areas to protect the 

17 1 President in terms of his privacy would be following: 

[B )Clearty. the dinin 

19 1 that general 

room and Oval Qffice Complex the study, 

area 

[ 10 1 really his private 

~totheleftoftheQvalC&e,was 

uarten. the Oval Qftice and the 

1111 reception area. T reception area to a tess extent because, 

I . 12 --, I I mean. obviouslv. that was an area in which there was 

rl3jaccess: . ‘

But in terms of 

I il I it was largely the Oval QfF 

rotecting the Presidents ’ privacy, 

ice, the study, and the dinrng 

fi6jroom area. 

Q And you feel that one of your accomplishments as 

I : i ; Chief of Staff was that you made those areas more private and 

[ I 9 1 arranged for less access; is that correct? 

I291 A Thats ’ correct. 

1:: i based on 

what would you consider - 

(2 3 I consider t 

Staff what wouM you 

[ 2 4 1 let me exdude 

P&tent, exduding - 

I251 A I think the study. 

r9my. 

IlO1 

r111these to 

). And 111 ’ ask you whenwer you designate _s. _ 

1121 

I131 

1141 

gGT d=umnt) 

’ tp 

)r from Mr. I&es’ mom to Walkway 1, 

t:&OUld ,.-. .,Fm-l, 

1171 A 

- Yrn or closed? 

[lelan openi 

I have to tell you that - I mean, thii map shows 

[ I 9) Walkway “4 

into Room 108. which looks like a door leading to 

. I do not remember a door in tiat area 

t201. Q Okay. Well, then leys leave it blank for the time 

rzllbeing. 

Whatistheroomnextto-itlookstiiearoomto 

i::ithe rfght of 108 with a partial room. or partial area within 

124)it 

1251 A Yes. 
3224 

Leon Panette, 1128198 xwurll, 

Page 74 

[Ii Q 

A 

Can you educate us as to whats ’ in there? 

Yes. This was the time that I was there George 

I; i Stephanop;ulo~k%%ze, 

II! And was he called Communications Director7 

151 A No. x, wasnt. ’ He was really an assistant. What I 

(61did was - he had been one of those that I had termed a 

[~lgeneralist and I made him an assistant to the Chief of Staff. 

Q Okay. So the bigger area, the whole area is George /E jstephanopulos's office when you were there. 

[lOI Yes. There IS a - if you look at that block next 

[ I 11 to - to the right of Room 108. there is a very small 

[II I reception area in whtch there was a secretary located in that 

[~3larea. and then his desk was located in the larger kind of L- 

[IrIshaped area. 

1151 0 ,,Oka 

&o 

Then in the larger, L-shaped area Ill ’ ask 

j ;iiyou to Put~~~~~E~~~~d~~~~t.) 

[I91 Q And then this would be his reception area, the 

tzojliile area you talked about where his secretary was? 

r211 A 

i22i 

Thats ’ correct. Off of Walkwav 1 - 

Q okay. 

(231 A 

Q 

-there was a desk there and a secretary. 

Why dont ’ we call that Reception Area 3 

:::;just want to put “Rec..’ or however you want to do it. Its ’

and if you 

Page 75 

t I 1 Reception Area 3. 

t21 A R. ht 

131 

[41 

g'M;yEg@g;pe document) 

151 Q Okay. Is there a door between 108 and Reception 

[6]AW 3. or is that just a - 

I71 A No, there is no door that accesses that area. 

Iiion this 

Q So the blank ink just didnt ’ go all the way through 

-whoever did this. 

1101 A Well, yeah, I guess I - I dont ’ know the date of 

[ illthis map. I mean. there are obviouslv chanaes that have 

i 12 1 probabfy been made. 

. _ 

Q Right Well, when you were there there was no 

I::idoor, corrqct? _. 

I151 A I nefe was no door. 

1161 Q Then 111 ’ ask you to kind of connect the two lines. 

[I71 

t191 

~~$tntnnara~t&re ’ document.) 

I 

Q 

IZ&pically open or closed? 

Was the doorway from Reception Area 3 to Walkway 1 

I211 A 

Q 

That was typically open. 

Okay. Was there a doorway between Reception Area 3 

I::iand Mr. Stephanopouloss ’ ofiia?? 

1241 A Yes. that was - I think they were shuttered doors. 

I 2 s I it wasnt ’ a hard door, but someone in that office could get 

Page 78 

I 1 I privacy by dosin those doors. 

Iii 

Q 0%~. A.shuttereddodl 

A I belleve 4t was a shuttered door. 

I41 0 Were the typically left open or dosed? 

I51 A Normal 

I61 

#!hey were open. 

I71 2 %% right. 

he wanted privacy, he could dose them. 

0 And then the area between Mr. Ste 

[i ; office and the Oval Office Complex induding the d! 

hanopouloss ’

I 10 I room, I take it theres ’ a doorwa 

rning 

betin those two? 

A Yes, there is. T f!e re IS . a very small - theres ’ a 

I :i ;small door that leads from the office that we designed George 

I 13jStephanopoulos. “GS.’ leading into the dining room. 

1141 Q Was that typically open or dosed? 

1151 A That was dosed. 

1161 Q All right. Do YOU know if it was locked or not? 

1171 A Idoiiotknow: 

1181 Q 

A 

Okay. All right. Are we all fairly on the - 

I should state for the record though that I had 

f :i 1 made dear to George Stephanopoubs thai he was not to use 

1211 that door for access into the Presidents ’ office - 

t221 0 Okay. 

I231 A 

r241entrance. 

- and that his access would be through the normal 

rzsi Q Had it been your information or your personal 

Page 77 

( : : knowled? pnor to you coming on and t@ta.&g s&p, that rvs 

(- L__~ did ‘ feel ~~ ree ~- to ~~ walk throuoh there? 

.i’ 

.- A 

Q 

That was my understanding. 

:4: It had been his office before when he was a 

i 5 : generalist? 

IF A Thats ’ correct. .-. 

I-: Q Okay. You made him into a specialist. 

[e- A Yes, of sorts. 

15’ 

.~. Q All right. Is the area at 3:OO leading from the 

[io;Oval Office to the outer area. is that an outer area -you 

[ 1: : said the door is usually kept closed. Youve ’ referred 

[ 1~: generally to the outer walkwa 

1131 A Thats ’ right. x 

as the colonnade? 

ose series of dots that 

[ 14 ; there are the colonnades that adjoin the Oval Office. 

ou see 

s o 

[IS 1 thats ’ normally called, you know, the colonnade walkway. 

I161 Q And would that lndude this area that seems to 

[ 17 1 more enclosed ust ‘ to the right of the Oval Office? 

t191 A thats ’ right. 

1191 Q 

tzojcolonnade. 

All riaht. Its ’ all still considered Dart of the 

t211 A It is. There are some chairs out there that I 

(221 uess some 

1231 8. R 

residents have used. Ive ’ never seen President 

lmton use t ose chairs. But its ’ realty intended as kind 

[24 lof - almost a porch at that point. 

[25!Used for that purpose. 

But rt really was never 

be 

Page 78 

[II Q Okay. Can you just mark that area that you call 

(2 1 the colonnade - if you could just write Colonnade. ‘ ” 

t31 

I41 

~~M~~s$a&dt!e document.) . 

I51 Q 

I76$z?? 

Can ou tell us what the areas in the lobby - if 

u all can see Lob ‘ r;Ny, ’ krnd of center left in our map of 

first floor-what would be the two area underneath the 

tslbbby? 

191 A The area to the -the first block to the left 

[ 1 o 1 below Lobby wouM have been a secretarial area. The area to 

[ 11 lthe right would have been my other Deputy Chief of Staffs ’

[12lOffice. 

Q Okay. Would it be fatiwltthat a -;-e&o-to 

I iii call the room to the left a reception area? 

1151 A Thats ’ correct. 

::76iArea 4? And Ill ’ ask you to mark it. 

0 All right. Why dont ’ we call that Reception . 

t1s1 

[I91 

~&tn;~;$&~~te document.) 

Q 

i:T&e office of your Deputy Chief of StaR) 

And then theres ’ a doorway from there leading to 

1221 A Thats ’ right. 

I231 Q 

A 

Harold Ickes is one of your deputies, correct7 

1241 That was - hes ’ in Room 188. 

t251 Q Right. 

Page 79 

~:;inil 

A 

3c; 

That would havebeen either B. 

r3jthet 0 

and then Evelyn Lieberman would have worked in 

ce. 

QI:;it-whowastbe 

Oka erfg’;nyu ’ to put IEB,” and then under 

ox 

I61 

171 

IsI 

I91 

I101 Q She succeeded Mr. Bow&; is that corn?&? 

Ill1 A mars coned 

Q AII r$ht. And ma 

jijje$if!e doorway DOG.” for !Ffwec?putsomewh= puty Chief o Staff, just 

I151 . 

I161 

~M~$&,.!$&$$re document) 

Q Andifwecoukfakoputthatontopoftheword 

i :i ~7bor1V infoo;. 12, where youve ’ said Mr. lckes was. 

1191 

I201 

1211 

~~Th&ne&me&$Jbe document.) _ 

Q If you know, was the doorway between Reception 

t:514 and Mr.~~v&~Frce open or dosed, typicalty? 

I241 

I251 Q And was the doorway, if there is one, between i 

OlCStarr Page 74 to Page 79 

- 
3225 

BSA Leon Panetta, 1128198 xyIJ(H., 

Page 80 

[ 11 Walkway 1 - I 

I z 1 Walkway pn c? 

uess there would have to be - between 

[31 

$ecneption Area 4 typ~celly open or closed? 

[41 0 Og 

[ s 1 to the north of Hall r 

This area we havent ’ been able to identify 

, getting back to the area of the study 

[ 6 I off of the Oval Off&. IS it possible that thats ’ a closet, 

17 I or does that .ob your memory that that could be a closet? 

I51 I d ont ’ want you guessrn but just - 

t91 A It could be a closet, % ut I - 

I101 0 Okay. 

A - I just honestly dont ’ remember having used that 

{ :: jdoor - if there is a door there havin used it. 

1131 Q Okay. All ri ht. well ’ ave rt blank. 

# 

?e . 

From the Oval 0 ice Complex which includes the 

I:: ldining room there appears to be a doorway goin 

[ 16 1 its ’ marked on the ma 

south and 

“Room 110.’ Tell us wha 

9 .. ‘

that IS, 11 

1171 

r 

ou know. And I can #I3 tell whether thats ’ inside or outside, 

[ 18 1 bough it has a room number. 

1191 A 

iIOilX?loW. 

I think this is referrino _. to Derhaos a mom located . 

1211 Q Okay. 

I::; Room 

A 

111 

Because to that area off of my office, which was 

where those areas - it opened up into the grounds. 

t243There is no room thats ’ located there. 

I251 Q Okay, all right. Do you remember a door leading 

Page 81 

[I lfrom the Oval 0fhc.e Complex room out into the grounds? 

12 IThere appears to be one on the ma . 

A There is a door that g ads out from the Oval Office 

1 :iCompkxldining room area into a kind of a patio area that is 

[ 5 1 sometimes used by the President for luncheons outside. 

176;there? 

Q Okay. Is that typically an open or closed doorway 

181 A Thats ’ closed. 

191 Q All riaht. Whv dont ’ YOU gut somewhere down below 

.~~. 

t131 Q 

[ I 4 1 a door that o 

All right. Did your door - did you adually have 

ned onto the - did the 

tl5joffices 111 EceptionArea2 108 &$~&$~~opoulostld]did you all have access to the grourids? 

A 

I :i i George Ste 

R 

I do not recall any access to the grounds from 

[ 19jReception 

hanopouloss ’ room or Harold lckes room or 

rea 2. I did have a door that bad off of my room, 

I 20 1 Room 111, that had - there was access to kind of a similar 

121 jpatio area. 

Q Oka And is thatdoorkindofmarked b aline 

I~~jovertotheleftofl r 

124 jkft. right. center? 

l? Orcanyoutellmewhereonl1 r. 

t251 A Actually, thats ’ a window. I think the door is 

Page 82 

1 I llocated more in the middle of that wall to the south of Room 

121111. 

131 

I41 

AQ Rqkztt: so right in the middle. 

I51 Q lt%esnt ’ look like its ’ noted on the map. 

161 A Thats ’ right. 

0 But theres ’ kind of a white - right in the middle, 

ii ia white area with a line through the middle of rt. 

191 A Thats ’ correct. 

t101 Q That would be it? 

t111 A Thats ’ correct. 

1111 0 Would that typically be open or closed? 

1131 A Closed. 

If you could put a “C” either on that or right 

;:B9;2: 

Q And then put “Patio” - I guess well ’ put “Patio 

I201 

1211 

k;“eM~tn~~rna&pe document.) 

I21 ’ 0 And Ill ’ ask you td put number 1 under the atio - 

12 3 1 

E 

ouve ’ previously mentioned the one south of the Oval Gf&43 

[ 24 ] OfI’IpkX. ’

I.751 (The witness marked the document.) 

Page 83 

[II BY MR. WISENBERG: 

Q You mentioned that the study had a lot of mementoes 

I: 1 in it, the Presidents study- IS that correct? 

[41 A Thats ’ correct 

(51 0 

16 1 mementoes? 

How was R furnished. if you recall. other than the 

171 A. 

[alon it to the ht. and then a couch located to the left as 

“ill 

I believe it had a small desk area with a telephone 

[ 9 J you entered e study. 

(101 Q And when you say “the nght.” thats ’ as were ’

c I 11 looking at rt on the map here. 

[121is that correct? 

Theres ’ a desk in the right; 

I131 A Im ’ sorry. as T 

I141 Q 

IlSlit. 

As were ’ looking at the map, as youre ’ looking at 

.--, 

I161 

I171 

Aa l&;uing my best recollection - 

1221 Q -Okay. 

I231 A - as I recall. And then to the - as 

12 4 I that door. to the immediate left. there would have 

ou went in 

izsjcouch: 

Lns 

Page 84 

Q Oka 

i:ifor the desk and pu r 

. 111 ’ ask you to mark - to draw a rectangle 

a [r ‘ on It, where you remember it 

t3jbeing. and then another redangle for the couch and 

[ 4 1 for sofa, so we wont ’ confuse it with open and 

ut 5” 

dos ez 

151 

I61 

~~M;tnt;E~3a~lt$e document.) 

171 Q Theres ’ a ueshon from one of the grand jurors. 

ISI A JUROR: dich wall is the sofa on? 

I91 BY MR. WISENBERG: 

[lOI 0 Which wall would the sofa be on? 

A The sofa would have been as you - the wall between 

i::iHallway 1 and the stu _ 

!::;study and the Oval 

Q Oka&$+edeskfs~ the 

il5, - 

CornDleX? 

A Thats ’ right. 

;::;study? 

0 Okay. Is it facing that or facing out towards the 

[I81 A Its ’ faci the wall. 

Q Okay. % right. So if you were sitting at the 

[:z;desk. you~be~ta$re ’ wall - 

1211 

1221 Q - to the bval olfice Complex. 

K;there? 

Is there an indiiual named Steve Goodnin who was 

izsi A Steve Goodin. 

z 

Page 85 

_ 

-~ 

Page 80 to Page 85 OlCStafr 
3226 

BSA Leon Panetta. 1128198 

..__ _____ 

Page 86 Page 89 

!I1 How do you s ell that as you recall, Goodin? 

:21 A Goo& G-o-b-d-l-n. 

:31 Q d-i-n, okay, all nght. Did he - I know you said 

I ‘ lthat you had ultimate line authonty over everybody in the 

’ 5 1 White House, but was he consldered to be out of your office 

6;in ‘ even a more intimate sense, the Chief of Staffs office. 

:7]or - 

illj - A Thats ’ correct. 

Q Youve ’ mentioned the desk and the sofa in the 

~~~~stucty. What else do you recall bein in there, other than 

1 zolthe mementoes 

x 

ou have mentionJ? 

A collection is that there are bookshelves that 

if:;are located in thal gudy that woutd be on the wall located 

[23]between the study and the Oval Offi+. and that the rest was 

[24]just - there was nothing particularly distinctive that I can 

~2s~remember other than, you know, small tables and, you know, 

Page 87 Page 90 

1 I 1 usualty tro hies or awards that the President had received. 

I21 6 So there were some small tables? 

131 A I believe there were some small tables in there. 

I41 Q On which one couM place these mementoes. 

151 A Thats ’ correct. 

Q Theres ’ a bookshelf against the wall leading to the 

176iOval Office correct? 

I81 A’ Thats ’ right. 

191 Q 

A 

Do you recall a rocking chair being in there? 

I think there is a rocking chair in there 

i i y ; approximately in that comer located across from what weve ’

[:2 ldesgnated as the sofa. 

1131 Q 

A 

A comer across. like catty-comer or - 

I believe it was in the area that is as I said. 

i ::i located to the south of where we desi 

8 

nated a sbfa. 

(161 

c:71 

; popem.right of the stu y? 

I191 

1191 AQ PSLe. 

I201 0 Al! right. Can you put “RC’ for rocking chaiR 

1211 

I221 

~~M;~&~<$e document.) 

Q And I wont ’ ask you to put “BS” for bookshetf. but 

i::!if you could just put “Books,” if ou coutd kind of write 

rzslthat in where you think the boo & are. 

Page 88 

i3i Q All right. Thank you very much, and well ’ have 

14 tsome more questions now that weve ’ got this portion of the 

I 5 I map marked out. 

I121 A Again, as I said, if there is such a thing as a 

I 131tv~ical dav. Notmallv. the interaction with the President 

I131 

[ 14 1 

But if the event was in the White House, then wo~!d 

1151 P he PresyenJ on the event, In wh,tch we would go over his 

roceed ,tiom the foreign po!icy beefing to a briefing for 

[ 161remarks. lndlcate how the event IS supposed to take place, 

[17)and then normally at the end of that, brief him on possible 

[ 18 Iquestions that he might get if it was a 

Then if there was an event, 

ress event. 

I:i;the event in the Oval Office. 

P would notmalty attend 

I211 So I would on most days be with the President 

r22lthroughout the momin 

I231 Q It soun %. B 

throu h, you know, the noon period. 

s lake 

A 

was almost on a continuing basis. 

Yes thats ’ Correct, Usual 

i::ihave been times when-Mad Iogo back 3r, 

I me?eth$ may 

. L 

il41 Or if - as, for example, durin 

[ls]l woukl have to go up to Capitol Hill an 

the bud et battie. 

8 meet w&the 

[ 16 1 leadership on Capitol Hill and meet with other members of the 

[ 171Con 

rlelthey 9, ad. 

ress. developing strategy or discussing other issues that 

I:: ! afternoon where we did not have 

So there was usually a 

p” 

riod in the early 

hat much access 

. Now, during tha.t time, he might call me, -X-t 

to - you know, mght want to know about sometMg 

ad run across on his desk. 

Then, usual In the latter 

i:!ias I said, maybe 3:00 Fo ’ about 6:00, P here would b&brief&s 

art of the day from 

Page 91 

r1lfor the President- W~WO&& ’ 

czlfor him, w if there was a budget cnM*sffkcdalin%m that he had to be nefed 

t31on or economic issue or any of a myriad of issues, obviowly. 

I 4 Ithat the President has to deal with, we would brief him on 

rslfofeign policy issues, and I would attend those briefings. 

t61And so we would have access at that point. 

il; to go to a rece 

Then, if he was to - after those meetings he was 

tion 

ts] normally wou lcP 

or a fundraiser or a dinner then’ I 

rlo~office to a 

not accompan 

ain continue to wo 

Ill 

M 

him and woudgo back to my 

on Issues. 

d 

[::!I said, if there were political meetings then when he 

then, particularly during the canipagn year. as 

r131rehmed from the event we might-there was a group thaw 

I 14 J met with him on politica/ issues, and that would be over in 

[ 1 s 1 the p,rivate residence, and that might run late into the 

1161 evenmg. And then,, obviously, I had access to the Ptesideti - 

1171 So that gives you at least a typical day. 

Now, on a travel day, if I went with the Pm&dent - 

[::&I a travel day then there were times when frankly I would 

c2oIhave access w/th him from the time he got ip to thetime ’ he _ 

ititwent to bed. 

Q And if you didnt, ’ you would not have access ot all 

i::iwhile he was gone obviously. 

1241 A Thats ’ right. 

I251 Q But either you or one of your - 

OlCStarr Page 86 to Page 91 
3227 

ESA Leon Panetta, li28t9a 

Page 92 

Ill 

I21 A0 YGeoutfes. ”es. So you even tried to staff it at that 

[ 3 1 level, that either lckes or Bowles could go with him when you 

I 4 Ididnt. ’

1131 Q Okay. What is your - I take it you are free to 

I 14 l continue this afternoon? 

I151 A I don? have a choice, do I? Yes. 

Q Okay. thank you. I needed to ask you that for 

~:76~schedulin purposes. 

[ISI 9* m going to keep questioning until the Foreman 

rlgltells me that; 

I201 THE FOREPERSON: You have ten minutes. 

I211 MR. WlSENBERG: Thank you. 

1771 

L--J BY MR WISENBERG: __. .__~ ._. 

i::leven 

Q 

[25itypica 9 

uantii 

Okay. So its ’ almost fair to say that you couldnt ’

“I was with him x‘’ amount of times on a 

day.” (/ou were with him almost continuo&ly in the 

Page 93 

I 11 morning, and not as often in the afternoon, but - 

121 A Thats ’ correct. 

i3i Q 

[41 A 

- frequent interaction. 

iiiil meetin 

Thats ’ correct. And then, normally, if there was a 

t5) then I woukl be with him In the evening. 

~61 pf ”there wasnt, ’ ?* hen I would not see him from, you know, 

[71perhaps 6:00 or 7:00 on. 

Q If you wanted to meet with him, what did you need 

I ii to do, typically? 

Cl01 A If I wanted to meet with him, I would qo to the 

i 11 j reception area. and then I would nom\ally ask Bettycurrie or 

[ 12 l Nancy if the President was occupied, and if the 

b 

indicated 

I 13 1 that he wasnt. ’ then I would knock and ao into t e Oval 

r14$ftice. 

i :z;sornebod 

Q Would there ever be a time when there wasnt ’

c 17 lthe r.O 

such as a Nancy or a Betty, there as a buffer in 

recep Ion area or Nancys ’ office? 

il6i A No. I - - 

0 Well let me rephrase it to say while the President 

i:iiwas in the Oval Of&e area. 

A 

I::idistinguish the two. 

Duri%,“,e,;g;gd &hgeav kii$$ina 

r 23 I Hemreich were alwavs there when th& President was locat 

iii ithere. one or the Ott&r. 

I251 Q “There.’ being the Oval OftIce. the study, or the 

_- -.-_ ___- 

Page 94 

I 11Oval Ofb Complex. 

(21 A 

r3ldesks. 

Yeah. they would be - theyd ’ be located at their 

I41 

151 2 

[ 6 J normally both. 

k%k one or the other would be there. and 

On weekends - on Saturda 

! i i and sometimes Nancy were there on i 

normally Be 

tV 

Currie 

I 9 1 there were times when the 

aturdays 4s we I but 

- you know like a Sa r 

might not be there because’ it 

[:!;ise. And sorn&imes the President you know would be 

urday afternoon. they would be 

112 1 working in the Oval Office and at thdse times there wouMnY 

. 113 1 be. you know, usually anybody in the outer area. 

[illwhere 

Q In the outer area. Youve ’ talked about the area 

ouve ’ drawn the desk due north of the Oval office and 

~16lrnarkefK. R as “NH.” Nancy Hemreichs ’ desk. 

1171 A Right. 

Q Sometimes that area that it was in was called 

1: i; Nancys ’ off&? 

i2oi - A Thats ’ correct. 

Q Would 

[g:;reception area, or did x 

ou also consider it to be part of the 

(r3lof its own? 

have more of an independent quality 

A Well. Nan could spot anybody usual1 

i::lthe Oval office. She woud r - would also - I mean, if 

going in to 

lsetty 

Page 95 

(14‘ 

[Isihim? 

Q Where would that typically be where you would greet 

A 

I :4: if - if the President was running late on hi schedule, I 

Well, there were a number of places. Normally, 

[ 1s fwould actually o over to the pnvate residence. 

I19: Q %ka 

I201 A And r might even take the elevator up to his 

(z I 1 

I22 1 Rim over to the office. 

rivate quarters and begin to brief him there and walk with 

(231 Q All right. 

1241. A Sometimes I would be oing over and he would have 

f z s Ijust come down from the elevator so t&t-wewc&ralk 

Page 96 

I 11 usually through this colonnade area. and I would even begin 

[z 1 bnefing him as we were walking. 

131 Q Down the colonnade? 

[4l A Thats ’ right. the area. If he was on schedule, 

I sIthen, usually, right after he walked into the Oval Office, I 

[ 6 lwouM be the first one to walk in and see him and then brief 

[ 7 l him at that time. 

nodding your head, but you have to - 

1211 A Yes. thats ’ amect. 

-- 

Page 97 

t I lwoukl be there during the work week, 

Q Oka . 

r 

Now lets ’ take an occasion duff 

i:iwhereoneofthese adieswouldbethere 

the week 

[ 4 1 Reception Area No. 1. 

Youwalkinothe n?

If the door is open’ from Reception 

I 5 v%xa 1 to @e Oval Office, wou!d you even stop and i 

I 6 I Bet!y Cume or Nancy Hemreich about what the Pres ?3 

uire of 

ent was 

17 ~doirg. or would you ust walk right in? 

A I mg 4 t not, although I always - I didnt ’ want to 

ii idisturb him if it looked like you know he was working on 

t lo 1 something. So my normai pattern Was to usually_ say to Betty, 

t 111 you know, “!s he working on anythi 

na 

in pafticulaff If I 

1121couldseeh1rnattheOvalOfficedes ,thenIwould,you 

L_. ,__l___ . . . . 

I181 Q 

1191 

All r$h!. You wouldnt ’ even be - 

A Thats right. 

I201 

1211 

AQ ---,zeded;.hat correct? 

Q Is that whether - you said that door was 

t:i;dosed. Would that statement you just made be true v&e 

W”Y 

r 

[24]it WaS closecj or open? 

1251 A Thats ’ correct. 

Pase 92 to Page-97 

-___ 

oicstarr 
3228 

BSA Leon Panetta, 1128198 

Page 98 Page 101 

[II Cl Okay. 

A Now, I should tell you that on the door into the 

i:iOval Office. that is. as weve ’ stated, located at 1:00 - 

(41 Q Yes. 

I51 A -that door does have one of those holes in the 

[ 6 Idoor in which you can look into the Oval Office and see what 

(7 1 the President ts doing, if hes ’ at his desk or if hes ’ not at 

te1 his desk. You can usually look in. And, normally, what I 

rslwould do if that door was closed first. is to look in through 

rlolthat hole. 

I111 Q Okay. 

(121 A I dont ’ know what they call those things, but - 

I131 Q Peepholes. 

Cl41 A Peepholes? Yes. 

I151 Q Would there ever be a time when one of the 

[ 16 1 secretaries - are they -would you call them secretaries, 

[ 17 1 administrative assistants? 

(181 A Yeah, assistants, I think, is the more proper 

tlsldesignation. 

0 Okay. Would there ever be a time when - are they 

f:!!more or less functioning as what is commonty known as maybe 

i22 jan exacutiie secretary& - 

i::;assistants 

A Thats ’ right. I think they were really personal 

executive secretaries. They were functioning in 

t25]that capa&. I know Betty Currie was placing the calls 

Page 99 

[ 11 that the President wanted to place. She was - she handled a 

r2 I tremendous amount of the mail as well as the communication 

i ; j that the President had to conduct. 

Nancy was doing much the same thing, although 

~:~Nancy. I would say, was operatin as more of an assistant in 

[ 6]tha sense that she was normally ? ookrng at events and looking 

17 ] at the Presidents ’ personal calendar, providing him backu 

rsonal notes personal mail, communications with frian 

I:$?& type of thii 

s 

on 

s. 

Q &odd voi ever walk into Reception Area 1. and the 

Normally, I would say to them, you know, what my 

A 

Violating your own setup. 

Yeah. I mean. tha Presrdents ’ entitted to a degree 

i::iof privacy hare. but obviousty they would never say to ma, 

tzs]you know, “Dont ’ gd in bed&s” - partiwbrty if I had 

Page 100 

(1 ]somathing sarious to discuss with the President, 

ISI 

Q Oka . Now what about thesituationwhereMR. WlSENBERG: Just tell me to stop when #s - 

141 THE FOREPERSGN: 

15 1 minutes are up. 

Stop talking now. Your ten 

I61 MR. WtSENBERG: Okay. 111 ’ ask the witness to ba 

(7 ]excused whik wa discuss what tima were ’ going to be back. 

t 8 I would you St outside and then well ’ let you know. 

141 TH?WtTNESS: Thank you. 

I101 MR. WtSENBERG: Thank you. 

Ill] 

!?r 

Mess excused. WRness recalled.) 

HE FOREPERSON: 

[ ::iyou that youre ’ still under oath. 

Mr. Panetta, Id ’ like to remind 

1141 THE WITNESS: I understand. 

I151 BY MR. WISENBERG: 

Q 

~:76~thingstoclaarupa 

The rand jurors have asked ma to ask you some 

?e w pomts . . Number one, 

11 B 1 that among other things, the stud4 was used or napprng by 

119 1 the Presidrt. yFsyou recall that. 

r 

ou menboned 

I.201 Q As a general matter youve ’ testified that the door 

r:ll ’ from Hall 1 to the study was open; is that correct? 

I231 A Yeah, when I -when I would walk through there, it 

(24jwas usual1 open. 

1251 II All right. When it woukl be open, and you woukl 

: I! see it open do you know whether or not the President wourc 

! 2 lbe in there? The bees that you saw it open, do you recall 

[ 3 1 whether or not the President was actually in there at those 

7 *.,- :I times7 --- 

f51 A 

c 6 1 is, we would 

Year usually not. because what would be &wning 

be mowng elther from the Oval office to the 

[ 7 1 dining room or from the dtning room to the Oval Office. 

[alwas not - 

lt 

It was not a place where I normally met with him. 

! q]lf I - the places I nOrmall 

11 o 1 business was either the 

met with the President to do 

&I al Off~cs or ths dinin 

Q When he was nappin if 

room. 

].!I ‘

r~z~typically be closed. me door from Ha 9 I 

in there, you know, UJUU a 

I131 A 

Q 

Usually it would be. 

1 to the study? 

I141 All right.. When he was in there - I think ym 

~15~words were reshng. regathenng, changing, relaxi 

I 161on th,e phone when he. wanted pnva from his sta ?I 

speakag 

, get awaj. 

; ;; ; na&;fi; W$JM d typcally be clos~when he was doing 

i:z;doing son! of thework in!&ra where he drdn? want k be 

If normal , rf he was changin orna ping Q 

tzl]bothered. then that door would be dosed. 

our knowledge, w+n ha 

Page 102 

(11 in there - som@nes I would go back to meet him, and I 

]z]would find&im m&study, and the door would be open. 

131 .~, 

(41 A So tivaried. 

Q 

tZ;woutdbecomin infromtheQvalOffrcaIn other words these would ba occasions whsn you 

I71 

181 

$ &ats ’ ht. 

- to Hal “9 1 and then the studv? 

,9i 

I101 Aa ~~~%tuldyouever-intbkindofan 

[ 11) instance when you came in - youve ’ alread 

r 12 ]Oval office through your normal entrance. 

corns n to ths 

ouve ’ said tha 

r13]doorway frnn?the+atGfficetcliatl l~usualtydand. 

i141 A Yes. 

Q So &s ‘ take a situation like that. You dont ’ saa 

~~~~himintheOvalOf%e. YouseethedoortoHallldosed. ’ 

I 17 ]Would you typicalty have any problem with opening that doa 

I la I in that situabon? 

ii9i A Normally I would knock at that door. 

t201 Q At the hall door. 

1211 A Thtisright. 

t221 

2 ause at that point I didnt ’ know whathar ha was 

I::lbrthebathroomorrhetherwasinVK~. Butlwould 

t2s]nonnalty knock. and he might respond. 

4z 

Page 103 

I&piilty not coma in. 

Q -+ncMyotldidn~?wqansa,ywwautd 

I31 A Normal thats ’ right. 

Q Oka. hd Itakeitthan itwouidbaevanrrxxa 

i!.isoiftha-Itakeit tx, n, th6res ’ going to be almost no 

r6]circumstance where you would open that dosed door from ths 

r7]OvalOffiastoHall1,aty icallydosaddoor-therewould 

teiraalty never be a cirwms P anca when you would open that 

,:;;~~jetttng some response after hawng knocked; isthat 

ill] A maysc0~ect. Q All right. So we wouldnt ’ have a situation wtma 

!::iyou go to that door, you knock. you dont ’ hear anything, you 

114 ]walk in and find 

A t&nalty what I would do is I would knock. I I 

oursetf - that just wouldnt ’ happen 

IZ4Mdn? hear any response from the other iiie I might crack 

(17]thatdooropenalittlebitfromUleOvalOlficeir;tothe 

118]area and then addrass the President again, say, “Mr. 

tlg]President?” 

1201 

I211 2 

tzzlpoint. 

k%% I got - usually Id ’ gat a response at that 

1231 Q 

I241 

fzslin.” 

.A 

All . ht And sometimes youd ’ be invited in? 

Rig%! Or hed ’ say, “Just a minute,’ or, %oms on 

~_ ._ ____~_____ __ .- 

OlCStarr Page 98 to Page 103 
3229 

051 Leon Panetta, 1128198 

_____~~. xMAx(lr) 

-- 

Page 164 

Q 

ii i in five minutes ” or somethrng like that 

Okay, all right. Would $0~ ever be told, “See you 

131 A 

Q 

Yeah, ‘ “Just a minute, 111 ’ be ri ht out.” 

iSI Okay. Ever any longer pen .J 

[ 5 1 like, “Ill ’ get back to 

than just a minute, 

ou later ” or five minutes or ten 

; 6 1 minutes or anything y. Ike that? 

A He was usually - usually if I called in and said, 

il j”Mr. President.” you know, and I would usually mention what 

! 9 1 the issue was, he usually would come out. Sometimes it was 

r :olfive minutes, sometimes it might be ten minutes, but it 

[ : 1 Iwasnt ’ usually much Ion er. 

I:21 Q Okay. & en that would happen - was there ever an 

i 13 1 instance when that would happen - let me be a little more 

[ 1 I Idefinite. Was there ever an Instance where ou shouted his 

I lslname or sooke his name. and he indicated t x at he would be 

Page 107 

111 

[2: 

Q E$doyoueverrecaUatime-lwantto_ 

A 

13i 0 No ou dont? ’

I41 A No.’ tydont. ’

I51 Q In answer to my previous question? 

(61 A Thats ’ correct. 

0 You mentioned you would sometimes catch the 

ii; President rmin to work down the colonnade; is that correct? 

I91 T?la t% correct. 

1101 Q If Im ’ pronouncing that correctly. Is that the 

[ 11 ltypical way he would come to work in, the momin ? 

[I21 113 1 the pnvat,“,s~~~~e,~~~~~~~~~~~~~~~me from 

[ I I 1 that colonnade path on the outside, even during the coldest 

[ 15 1 weather, and then usually enter the Oval Oftice at that door 

1161St 3:00. 

i :i ;a clock. 

Cl Okay. And youre ’ referring to the - like hands on 

1191 

Youre ’ not saying at 3:00 in !he afternoon. 

L 2. l at approxi~ate~~v~~.yeah. tt s h doOr um to-ted 

i 16 jwith you in a minute or five minutes or ten minutes - you 

[ I 7 1 would usually wait in that area? 

;:;;ofhce. 

A I would - Id ’ close the door and wait in the Oval 

Q 

~:~~Dffice and 

Okay. You would dose the door between the Oval 

Hallway 1 and wait in the Oval Wee. 

t221 A Thats ’ right. 

Q In that sttuation when he would finally see you 

I::;when he would come out, wasihere an instance when he wasnot ’

tzslalone? 

Page 105 

[II A No. 

0 Okay. He would always be alone in that situation, 

I: i when you would Rnally see him. 

I41 A That was - yes, yes. 

151 0 Okay. 

A He would usually come out alone and he was, you 

I :] know either - if he had come out of the bathroom, he was 

[e 1 still putting his coat on sometimes. 

191 Q Okay. Do you recall any situation where he told 

lojyou - Im ’ talking about these &rations you identified, 

i I 1 just a minute, five minutes or ten minutes. Was there ever 

lz jsuch a situatton like that when he would ultimately invite 

I 13 1 you into the study after he was read 

A 

for you - to see you? 

Normally not. Norma I he would come out, and then 

Ii: i we would do our business in the Ova b office. 

1161 Q Oka 

f 

_ Where would he ty 

117 jthere was a typical rme when you might R 

ically be in the study if 

nd htm in the 

Page 106 

[ 2 5 1 going to be coming out. 

would t at also be the typiil path when he 

!::iwould be heading to the living quarters. when he woutd go 

rzslback? 

A 

I::!back.- Sometimes he would gobackthretgbttratdoorfromthe 

Yes. There were usually two ways that he woutd go 

[I 1 Oval Office to the Colonnade. He oftentimes m’ 

t2jthrough the door in the Rece 

Page 108 

ht exit 

.P 

tion Area No. 1. l? at glass 

13 1 door was often used to go n o the colonnade area. 

I41 Q 

A 

And that s a door we havent ’ marked yet? 

Ive ’ marked it as dosed. Normal 

Iz;ctosed. I marked it as “C.” Its ’ in the Reception 

[7 11 in the comer. 

Xre . 

th,ttomr was 

ts1 Q Qka That top right - near the top right. 

[91 A That!s ht. 

I101 Q 

illj 

I no&%eres ’ a V - a V-shaoe - 

Aa wsrigM. 

_- 

1121. - south of that other door. 

[13llS? 

Do you know what that 

I141 t Thats ’ not a door. There is a window there. 

Okaty 

There s one thing I want to clear up. Lets ’

I:z;go back to the Ova office Complex dimng room. and youve ’

; ;;: ;got the “PD” for 

A &sconect 

ntry door, correct? 

Q And I think we have marked as dosed the door from 

i:iiwhat you t~k~.~~to the dining room, correct? 

t211 

Q T’ 

::$;a doorway from t!!Fa 

Ity do&?+ And you atso said that theta is 

pantry out Into, you think. Watkway 1. 

1241 A Thatscorrect. ’

i25j Q Is that - what I dont ’ recall is. did you say - 

-” 

Page 109 

t 1 j is that typically closed or open? 

I21 A tf the steward is there, that door is usually open. 

131 Q 

iri 

Qkav. If he isnot there? 

A Us&yctosed. 

Q 

/ : ) a T/O.” because thafs dependent on the circumstances. 

okay. So why dont ’ we put out in the hallway there 

171 

181 

~I.M~&g&p~ dO-=N 

tK;there. correct? 

Q Typicallydosedtfhesnotthare,openifheis ’

1111 A Thatsconect. ’

Q Now. in terms of his general movements - weve ’

~:$~talked about when he came to work a the morning and when ha 

! : : 1 left. In te!? o~f?%?k?$d~!&\nswer. 

ii6i Q Yes, sir: 

bmes he would watk dorm 

era were some timeJ 

tzolthat-thatupperbuildinta&ereinthemaoI 19 jwhen he might walk throu h the colonnade that you see along _ 

I211 Q. ‘ Okay. - 

A - and he would access thro 

I::ithat Desk No. 1 is and actually 

(24 IOval Office, Those were rare, 

c2s1would do that. 

Page 104 t0 Page 109 ----~- ---- 
3230 

Leon Panetta, lt28f88 W4@ 

Page 110 

And you all see that? 

Page 111 

Ill BY MR WtSENBERG: 

;:;wete talki 

Q North of Walkway0 is - thats ’ Fhe Desk No. 0 you 

x 

about wh?re the Sectet Sefvii sits. 

l4l 

Q EZi!~%%dufingtkida Itakeifhewouldjust 

I&v& around the-he wouldnt ’

I:;- 

during the day when hes ’ waUu~~,~!n%~e?&hite n==& 

Page 1!2 

bading into-nd then 

his usually means of 

rornotthepantrydoot 

Page 113 

Page 914 

I I I Of@!, dignitaries. and he bad to prtpare eitbr drinks or 

I:$E?% 

*know meetvadousmque6tsofthevisitom 

-~fb&dpzparethedrinksinth8pantryaivj . 

t4~thenbringthemhtotheOvalOftice. 

~~~~~ht~~P~*~~? 

a Sothestewanlisgoingtotypbnybethemday 

.E 

Page 115 

-to-~ 
3231 

BSA Leon Panetta, 1128198 

Page 116 

I I I at work in the Oval Office before YOU came to work that 

j 2 ] youre ’ aware of? 

. A That was rare that he woutdsthat ’ he would be in 

t: ithe ?a1 O%ce before 790 in the morning. 

Q Were there ever times when he was inthe Oval 

~~~Wmarea. or the areas youve ’ testif& he usually was in 

[ 7 ! before - while you would have been at work, but before you 

[B 1 saw him for the first time in the morning? 

(91 A 

Q 

Im ’ sorry, say that again? 

I think you might have partially answered that 

I:?lbefore. Were there ever instances where he would be in the 

I iz]Oval Office or adjoining areas after 

I I 3 I before YOU had seen hrm for the firs 

ou were at work, but 

r. trme that dav? 

il4j _ A Oh, yes, es. 

[I51 Q 

(161 A 

Okay. Ti!at couM happen - 

That s right. He might -while I was still 

(171 holding a staff meeting, the tatter staff meeting, he might 

118 1 have come into the Oval Office. But normally they alerted me 

t1g]when he came into the Oval office so that I could brief him 

tzo]quiddy when he came in. 

(211 Q And theThe would bewho? 

t221 A 

Q 

“They” woudrbe Bet)reCunie or Nanr#~mreich. 

All right. Tell us a litt bit about the 

i::!House intern program. What is that? 

t251 A As best as I understand the intern program, there 

Page 117 

111 is an Intern Oftice that operates that r 

12 ]given time there are approximately 2 &I% 

ram and at any 

306 interns that 

t3]are ass’ ned to various areas throughout the White House and 

]4]the Old&cutive Office Building. 

t51 I believe that, you know. the number can total as 

ts]many as perhaps a thousand or twelve hundred during one year. 

The Intern office setects the interns and ass 

iii the interns to the different areas. 

ns 

I was not - I was no p ‘

ts]familiar with. nor did I request or select the interns that 

rlo]workedin~yof&e. _ ,. 

1 

u ukay. And you sard as many as a thousand might go, 

i :: 1 through in a year. 

1131 A That is right. 

Q How many if 

[ ::;itsetf at any one time? I don 

ou know would be in the white House ~ 

J mean lib at 3 odock ’ in 

[ 16 1 the afternoon. but at a particular - as Opposed to over a 

1; ; ~~~~~~~~~~~~d~~~~~e~h~~t~~~ g;Juy 

t I g] testimony on that. 

Page 118 

I151 A Oh, yes. 

(161 Q Less than f&y? 

I171 A Yes. 

1181 Q 

A 

Less than twenty? 

I:,’ ! both - you know there are three floon there both 

Well. I mean the West Wing is a big place, it is 

1: 1 I underneath the ftoor we have st described ’ as well as a 

t22]third floor above it. so it is rea& difficult for &e to 

tr3]say. you know, where the interns mght be located. 

But, at least as far as I was concerned I - I had 

I::ivery limited access to interns and did not see that many 

LIlthere. 

Page 119 

Okay. SO you wouldnt ’ have even seen in your area 

I141 A As I said, I - I discouraged the use of interns in 

tls]that area, because I have always - you know, I appreciate 

116 1 the .fact that Interns have the o 

r 17 1 Whtte .House. but work that IS .8p 

ortunity to work In the 

one n the White House is very 

[ 18 ]sensdrve and I was very concerned about the use of interns 

t~g]on a regular basis. Particularly in the Chief of Staffs 

r201office. 

Page 120 

TheChief ’ of Staffs office. How about the Oval 

I::~Offtce, Oval office complex. Receptii7+ea t Study-the 

[II larea 

rls]most b 

ou have talked about is the most - as ai area 1 the 

rlslthere? 

nd of private area, how many interns, typically, 

i17j A None. 

I181 Q Okay. And then, unless there is an unusual 

[ 19 Icircumstance like the shutdown, none in your area; is that 

r2o,correct? 

1211 A That iscorrect. 

Kiand 

Q When was the shutdown? Was that - was that fall 

- fall and winter, fall and late fall of 957 ‘

A tt was Janua 

I::{recall correctly, that we had %e 

I think early January of 95. ‘ if I 

government shutdown. 

2 

Page 121 

111 Q All tight. 

A 

!:iand. I thiik thaj would have been - it was during the 

Because we wem in bud9at negotiations at the time, 

/ : ; Chnstmaa~,t$ &~~t$sd$$ .JJ;&pef;z5. 

161 

171 

t ;t$ve that is right. 

181 A JUROR: Ninety&. 

191 FOREPERSQN: Ninety-six. 

1101 A JUROR: Somewhere in 96. ‘

rnj (Simultaneous speaking bv iun%a.) - 

A I 

veah - no 

QUeSS thafS ’ right IM sorry;yeah, 

- Im ’ somr. the etectton was rn 94 ‘

p?.use - 

i 14 i it wis’ actually a 

r151So let me co rrecr 

ear afte%rarrJs that we had the shutdown. 

Q 

myself. I think it was January of 98. ‘

Okay. And had there been-had there been a 

I :76; briefer - lie one day shutdown the Thanksgiving before that 

I 18 1 January of 987 ‘

~:~&riods 

A I believe there had been. Llhiim.llwere_&~ _ 

of a shutdown we had at that time 

Q 

1:: i went to work for 

All right. The - do you &II how many interns 

1231 A 

ou during that period if - I mean 

I &eve at most maybe two but gen&lfy there 

- there was One. My regular a&stat&s Jennifer 

~~:%nura. atid she was always on duty for me, so that if 

- 

Page 116 to Page 121 
Page 122 

(11 someone was answering the phone it was usuaky one other 

(2 1 intern that was domg that. 

i:itime? 

Q Okay. So it could be as - as few as one at a 

I51 A That is correct. 

Q Do you know whether or not Monica Lewinsky was one 

1761of the interns who manned the phones during edher of the 

I 8 I shutdown oenods? 

3232 

BSA Leon Panetta, q/28/98 

--____ ~ ~~____~ _-z:; ‘

Page 125 

[il 

I2i $ \re%&other - IS there an extra level on - 

13 I not In the West Wing of the Whne House? 

A I - I believe she was and I didnt ’ - I mean. I 

[ :ijdid not recollect that until I obviousli saw her photogra h 

(111 as a result of the disclosures that had come out And t K en I 

112 1 recall that she was one of those that had come over for, I 

(13lthink. a couple days to answer the phone. 

[I41 0 Okay. 

A In that reception area, called - designated 

I:z;Reception Area No. 2. 

I171 0 Okay. A couple of days to answer the phone? 

I181 A 

Q 

That is right. 

Would that have been -would that have been 

I:zifirst time you met Monica Lewinsky? 

1211 A That is correct. 

i22i Q NowA Because again - ust ‘ so - for the record here, 

i::lthe interns that were assigned to 1 he Chief of Staffs 

~zsloffice, which would number, as I understand it. somewhere 

the 

Page 123 

I 1 I between d-raps six ore’ ht at the most, they would work at 

[z lthe Old E&utrve Ofhce &ilding. handling mail in the Chief 

r5lof Staffs office. So I would rare y see the mterns that 

14 Iworked for me. 

[lslare spread out throughout that area as well. 

i:tithat lar 

On the third floor there are additional offices 

- there are three main areas. 

[IS IOne is 9 

ely contain the r&s 

he Courtsets ’ office on the third floor, the second 

I 19 ] large area is the L islative Assistance area, and all of the 

1201 Legislative people “;f tat work under that individual. And then 

121 lthe third area is the Economic area, the National Economic 

122 ] Counsel has its offices up there as well. 

I231 There are otherqbut those are the main ones. 

Q Okay. NowjustsowearenotaMfused a 

~::~particular map we have here that is our copies of LP-1, at ‘

Page 124 

[ 1 lthe top r@ht it says “first floor.” Is - is the - is the 

~~~upperlevelandbwer(evet-offto&right-bthemap 

[T)map we are took~ng at at least exce for the areas that say 

14 ]we have been dealin 

[ 5 Iwrth. are they - are t 8 

with and the rooms we have been dealing 

[6]fil-St floor? 

ey considere - are they called the 

[71 A Yes the are. 

Q Okay. & they are actualty the middle level of 

/:/the .-, West Wina? 

I101 A -That is right. 

0 

I::ilf they call2 an 

Okay. And what do the call then the tower level? 

I131 

$hing other than lower &vet? 

ell. used to call it the basement. 

I141 Q Okav. And thenI 

I 

, 

il5i A The third floor. 

Q 

/:76;second floor? 

The third floor. So there is nothit called the 

1161 A Not real1 . 

1191 Q On the XI 

A 

est Wrng? 

1::; chucklin 

,;,,I i8 

) 

I mean thats ’ - that may have been m 

Im ’ sure the elevator 

- I us to always call it the thlr 3 

robabty says two, II 

problem 

ut 

floor. 

Q Okay. So the third floor first ftoor basement in 

!::lthe West Wing. And then there is another level & the - in 

[25]one Of the other wings, correct? 

OlCStarr 

- 

[4! 

i:; 

; To Gsponse.) 

ou said there are three levels in the West W 

16: A That is nght. 

[7i Q 

A 

Is there another revel in the East Wing? 

Maxwell. The First Ladys ’ offices are located over there, and I 

Yes. There are offices over in the East Wing. 

rlo:believe there - there are Legisla:rve - part of the 

I 111 Leglslatrve offices are located rn the East Wing as well. 

I121 Q 

A 

But is there an extra level, in term of - 

I believe there is. I am not that familiar with 

I ::;the East Wcg, g;r. I spent all my time in the West Wing. 

1151 

I161 A But r believe there is a second level. 

I171 Q You are not sa 

rlelthat extra -A on&at extra leve R 

ng ‘ the First Ladys ’ office is in 

1191 

,201 0 Okav. 

&7 

as 

.--a 

i:::0ffiCe. 

A I have never actually been to the First Ladys ’

1231 

I241 

1251 ’ -. 

Page 126 

I11 MR. WtSENBERG: 

(21 has entered the Grand Ju 

Let the record refled Mr. LJdotf 

room. 

On the West - 8 

i:;third floor of the West Wing 

est Wing, which you have called the 

uIro 

u 

r51L 

7 . 

islative. something abo 

have got - ou mentioned 

Legislative ma & ers, is that 

161ca ed - rs that also called office of Legislative Affairs? 

[7] A That iscorrect_ 

t&Ice? 

Q Okay. And you have got White House Courts&s 

1101 

[Ill A Q That is r%h- ’

A 

And the amomic area; is that - Economic - 

1121 National Economic Counsel Area. 

Q Okay. Economic Geuneet-Area. -Andwtlvwenk?he 

i::;White House Counsel when you were there? 

1151 A The White House Counsel - 

I161 0 As Chief of Staff. 

1171 A - .wt?zn I was Chief of Staff were Lloyd Cutter - 

~t;~;there for an mttlal pencd. then Ab Mikva came tn. and 

,_<,-.-.. 

I201 

I211 

I221 

Q Mr. Quinn? 

Aa Mdayinn. 

i23j 

I261 

I251 

A Frank (sic Quinn. 

Q And was b r. Quit still there when you resigned? 

A Thatiscorred 

a 

Page 127 

/11 Q okay. 

I21 A Jack Quinn. 

t31. Q . All right. From what you said earlier about the 

14 lmtems. what ts the - ts this - this area (indicati 

I 5 lthp West Wing that we have been baking at on % 

) of 

IS plan. is 

[61tttts what you would call the - is this known as the southern 

171 half of the West Win 

I 8 1 are aware of like so s 

or is there any designation that you 

hem batf of West Wing? 

191 A Im ’ not familiar with that term. 

you would call the 

i13j Q Again, aside frcm areas that are designated as 

I 14 Iupper level and lower lever? 

I151 A Thatiscorrec3. 

I161 Q Over on the ’ ht here (indicating)? 

1171 A Thatisco nez 

Q Okay. From what you have said about the Intern . 

t:89iProqamthen ouhavenothirqtodo-Itakeit-withthe 

(20) hiring of 2 in r 

1211 

;IS? 

tZ;intems? 

Q The - are you ty~icalty responsible for firing of 

A Well normalty the intern office itself oversees 

(::{tbe - you know. the behaviorof ’ the interns, but it would 

Page 122 to Page 127 
3233 

19. Leon Panetta. u28/9a 

L- --. 

--- _____~ 

Page 3 28 

: L ; not be out of the question that if we saw an tntern edher 

: z -not acttng appropriately, or being out of line, that we would 

i 3: not take steps to deal with that. 

::‘ Q When 

: E : through the interns o 

ou would do that wouki you typically go 

f? 1c8 r&elf, ,or would you sometimes 

[c : just act even without doing - wrthout going through the 

j - : Interns office? 

I?: A Well, normal1 

: 3 :would - would deal with tha Y 

my Deput 

, and I 

responsible for personnel 

wou Y, d tmagme she would 

I 1: : at least Inform, or tell, the intern offkx what should 

A Yes, that is - that is right. I was not going to 

[ :i isay “Pfease ” to the intern office. We were going to tell 

I 19 I the& that a&ion needed to be taken. 

1201. Q And what is it that the interns typically do? Or 

12 I j ts thee 8 typical thin 

I 22 1 different areas of the % 

because they are in so many 

OB? 

ain. it can vary. But if, you know, for 

appropriately, or they were 

ey were yellmng, or 

Page 131 

: : that kind of access 

I_. Q How 8xctusiv8 is it. in tears of - do you know, 

: 5 t for instance. does one out of every ten applicant make it. or 

; : : is it - 

15: A t dont ’ know. 

[6: Q You dont ’ know that7 

r-. L , A No. 

!s: Q Now is this the same as a White House Fellow? Do 

; a: they still have something called the White House Fellows? 

f.^? A No I think the fellowshi 

P 8 

pro ram, or the White 

i ; ; f House Fellows program, that is separa e an 

r 12 : intern program. 

apart from the 

113: Q 

[ ? 4 : that correct? 

That - and that would be far more exclusive; is 

~::~fellowship 

A That is correct. That is - normally the 

r 

[ I 7 1 have peep Pe ”i! t 

ram, as I understand it, is one in which you 

at first of all have - are usual1 much more 

[ I B 1 mature, have more training, and will 

[ I 9 1 a position for a longer 

actually 

nod of time. 

L assigned to 

Q The - t%y are later - they are - typically 

II?&ese Deoole are later on in their Drofessional career: is ’ 

i22jthat cdrrect? 

A 

t:: !who is workin 

That is correct. Normal for example SOmeone 

I z s 1 become a Fel B ow. and then - as part of their. career 

at th8 State Departmen ?’ want - may want to 

Page 129 

11 ;shouting or not acting in a mature manner, or - you know - 

rzlwere - rf we had found out that an intern had somehow been 

i 3 j involved with the local police, I mean those are all the 

f 4 : kinds of things that woukl concern us. 

And if it cam8 to my attention of the attention 

[iiof. as I said, niy Deputy, we wouM not hesitate to take 

17jaction. _ _ 

Q My question was -was not -was not clear enough. 

i!iVVhat I meant to ask you was what are the typical duties of an 

Jioiintem. 

(111 A Im ’ sorry. 

Q Is there any way - is that so broad that there is 

i :: j no way you can really characterize that? 

A I think it varies. You would abnost have to ask 

i::ievery office that is assigned interns what responsibilities 

tl6@8y gave them. 

117: 0 

118 !intern? 

How long is the typical tenure of a White House 

A Normally my u~e~tandi~ is that it is for 

j:Ziapproximately a quarter:which would be. you know, thr88 - 

121 jthree months, three to four months. 

I22J Q 

A 

What happens to most of them when they leave? 

f23! Normally the interns - again, as far as I know - 

(24 Jwould return -the purpose of the intern program is to give 

12s Jyoung people exposure t0 the Whit8 tiOUs8, and t0 its 

Page 130 

I 1 Jooerations. and then usually they return back to their 

i 2 j graduate school. or ~fess~onalschool? ‘

A I thtn - aaarn e can vanr. but I think 

i G itypically they are colksge $e: * 

48: Q 

k 9 1 respons~Mity? 

I take it they an? not typically jobs of great 

ll91 A They certainly shoufdnt ’ be. 

fill Q They should not be? 

1121 A No. 

. t13: Q Are the 

A Yeah, I t 

more - are they more honorary type obs? ‘

nk they -they are jobs that general 

: : : i involve, you know, moving papemork, 

ly 

or 

116 1 phones. Or, 7 

ou know, answering 

[ : 7 1 supervised. # 

ou know, dealing with usual y areas that can b8 

hat IS what one would hope. That certainly was 

[ 18 1 the case with regards to my oftice. 

Q Is it considered to b8 a - a 

I:: ! better word - for som8body to become a 

lum - for want of a 

&it8 House intern? 

-A I think - I thmk it is an honor for someone to be 

t$: ~seleded to work in the Intern Pr 

8 

ram, and then to have the 

J23Jopportunity to work in the White ouse. 

t24 1 honor for 

Thats ’ - that.is an 

an one who is &8&d, and the 

t25Jas an honor I8 cause not many people ha ~~httov~~ tha -you know, 

1 I1 development, and might enjoy working in the National Searrity 

Page 132 

I 2 I operatton, as an exampl8. 

Q 

~$vith this, but I - I take it that polihcal connections can 

I dont ’ mean to suggest there is anything wrong 

[sJ la 

tsJl;ta!conect? 

a part in helping one get a Whit8 tious8 internship: is 

f71 A Well, I - I never S8led8d interns for my off&. 

[ 8 1 but I think it is fair to say that if someone who - you 

[ 9 1 know, was a sup 

I loJsorn8thing for a p”. 

rtef of the President wanted to by to do 

JllJsomething. 

anMy member that that wouM count for 

1121 Q You - and from what you said you would not 

[~~J~~l~evaluate - assumin t then? i5anev&atianOfen 

[ 14 1 tn em - and I dont ’ know tha there is, if they are only 

tlsJthere for three months - but assumin th8r8 is som8 kind of 

[ I 6 1 an evaluation like an employ88 wou Ii? 

[ 17 1 typicalJy do that? 

get you wo&d not 

II91 A No. 

Q 

tE!an evaluation of sorts? 

Except for the extent that ~ns~~~ or firing. 

A If there - if there is a quick evaluation then we 

!::iwoutd ad on it. But1231 Q You would call that “an on the spot evaluation”? 

(241 A That iscorrect 

t251 Q You said that you beIiive you remember - a&ally. 

* Page133 

(51 A That iscone+ 

Q And we have rdentifred the budget shutdown, I 

~76~beliive. of January 1996 and a 

;e.;around ~~nks~~~ of&’ ’ is th%%%%abr shuMown 

gh 

I loJshutdawn, workin 

But lbo not recall her doing the first 

rn the office the first shutdown. I 

tllj~~~ve~was~ second shutdown she worked there. 

Q All right- Do you have any idea wtmther or not 

i&tey adually do have evaluations of interns? 

I141 

1151 

$ ;$ux;,m8an, I woukl - 

A I wouktsu~ 

I :76fmean I think the intern o 

[ 1 a 1 how ititems were doi 

p 

that they would beoluse they - 1 

c8 would want to keep beck of 

r~s~knowledge that that i%e case. 

. But I cannot tell you of my own 

Q -tbwtypiQt*it,iny6 .. 

t Z! fknowled e for an intern to get a . 

[zzldirectly &er his or her internship? 

a~~~~ 

A It can - it could happen if the intern Was someone 

f :: 1 who was patticulady msponsibl8 and dii a good job and 

[ 2 5 1 wanted to - you know - to move on to a position. I have ‘ to z 

-.- ~._ _ _.- -- 

Page 128 fo Page 133 OICStalT 
3234 

BSA Leon Panetta, 1128198 x-1 

I : : use an example. 

Page 134 

The office that I had on Capitol Hill as a 

i 3 ‘ ~Conoressman. if there was an intern who came in who was verv 

i J igood and did their job very well, that we mi 

i5:consrder that intern for - you know, for a JO .%

ht very well - 

c 6; permanent job. 

For a more 

And I - I think that might be the case in the 

I ,’ j White House as well. 

Q Do you - so if I understand your testimony - I 

[ Iz jdont ’ want to put words in your mouth, so correct me if I got 

[ 1: ; if wrong, it is not typical but it could happen if - if a 

( 12:person was ve 

A ?hat IS coned. 

responsible had done a standout job? 

[13i 

0 You have told us how - that generally you didnt ’

I ::iwant interns in this area, you didnt ’ want them in either the 

I I 61 Chief of Staff area, or the area around the Oval Office; is 

[ I 7 l that correct? 

A Yeah. I mean I - I maan just so you understand, 

I ::!I dii not want staff to be wandering through there. 

I201 Q Much kss interns? 

t211 A Much less interns. 

0 All right- Was - was one effect of your being 

i::;Chief of Staff that there was tighter rein on interns, as 

t24jwell as staff2 Is - 

f-251 A I believe - well, I mean. to the extent that we 

Page 135 

rlwere - we were contrdling staff, we certainly would have 

r 2 lcontrolled interns. 

Q 

I i ; remember? 

There wasnt ’ a specific intern problem that you 

[51 A No. 

[61 

I71 

Were there -when would the 

[ jH~~~~~~~~t~~~~~l~.~en interact with the 

it be just on parernontal occasions, or to 

[ I 11 have a picture taken once or twrca durin their tenure? 

I:siwould take 

[ 14 ~obviously, 

A_ t~;p~o~$p;or&~;z; $e president 

if there were events on the. south law;. you know, 

115~interns mrght well be invited to attend those events, or 

( 16 1 perhaps even receptions in the white &use. 

But it was 

! : i 1President ’ wouM 

la 

intera 

~w~rh~in~;;ons that the 

[I91 Q 

tzoloccasions? 

So, fair to say overwhalmingly on ceremonial type 

t211 A 

0 

Ceremonial. social occasions. 

Do ou recall any interns dunng the time that you 

[s:iwere Chief of Sta ffy- bemg fired? I want to make it - and 

t~ctlet me just say I want to make a distinctjon between fired 

tzstand transferred. 

__-_.__- 

Page 136 

Do you recall any 

I[; iwere in an intern status? 

interns being fired. white they 

A 

i : I oftentimes 

Well I mean I recall that Eve n Liebermann would 

ou know, axpr&s concern abo uV erther a 

I 5 1 particular in *r em or - I mean, she was - she was a tough 

i 6 @iidplinarian and, 

[ 7 1 correctly, or if they 

ou know, if somco~ 

I$ 

did not dress 

haved inapprdpriatety she would not 

I .~, B I hesitate to act to - vou know. to disdoline them in some 

f9way. 

What that 

i ff ldefine all the particu -r ar steps she ma . 

articular action would be I - I cannot 

have taken to 

I 12 tdiscipline peocrte. But she would de L. 

i ;3ipaople ona ‘ r6 ular basis. 

rtelv discibline . . 

1141 Q gfhe - do you recall any being fired during your 

(15 1 tenure, that you were aware of? Any Interns. 

I161 A Fired ou mean beirg111 ’ Q Asked?0 leave the - 

g 

articular 

ut I 

i 22 1 cant ’ recall this artiibr instance. 

Q & you recall any interns being transferred from 

i::ione area physically to another while you were Chief of Staff2 

I251 A Do - I do - I mean. I do recall in this 

Page 137 

[ 11 partrcular instance that -.that Evelyn Liebsrrnsnn exprssssd 

12 1 cnncam about the behavror of Monica Lawinsky. 

131 Q Okay. Now was that while - you know we have 

[ 4 Igot - were yuu aware that after she was an intern she took a 

t 5 1 

P 

ad posrtron in thus Ofhca of Legislative Affairs you have 

[ 6 1 alked about? 

A I - Im ’ aware of it now and I did sea her 

~~~periodically. I think in the halls, somehmas when I would 

[ 9 1 walk through the halls. So I - I had assumed that she must 

( 10 1 have gotten a job some place. or at least was still, you 

1111 know, operatin as an intern. 

Q gkay. But you didnt ’ know at the time that she was 

i ::; in the Oftiqa of Legtslative Affairs? 

(2 4 1 going to call lt the O-L-A. is that okay? 

1251 - A That lsfme. 

Page 138 

r11 Q You all call it that ever? 

121 A I dont ’ think so. 

The - you dont ’ - since you didnt ’ even 

(6]West Win 

you dont ’ know whather she was in the 

OIA office or the East Wang OLA office? 

r7i A That is correct. isi Q 

t:i{gp u 

A 

Okay. Lets ’ talk about sincs ou recall - 

t i i lbvrth & 

I mean, I have to tell you, I -!would sometimes 

to the West Wang of the Legis ahve Office to deal 

e Legislative Assistant, the Presidential Assistant in 

[ 12lcharge of Legislative Affairs, and I do not recall seeing her 

[13Jup there. 

[I41 Q Monica Lewinsky? 

I151 A That is correct. 

0 Okay. You said that 

;:76;Evefyn Liibermann and - and - an dy 

ou recalled incidences with, 

j~sjme - let me strike that uestion. 

may I just ask - let 

I191 MR. WlSENB%RG: 

izo jeverythin 

And - and - Im ’ obfiiious to 

t 211 when it is % 

but the questioning, so when you - I would ask 

reak time if you woufd just shut ma up, please, 

tz2jMadam Foreman. 

I231 FOREPERSON: Oka . Iwouldba happy to. 

I241 MR. WlSENBERG: dank you. 

(251 (Laughter.) 

Page 139 

- Evefyn Liibarmann coming to me and saying that 

[221&e dii not like the behavior of-of this indnriclual, 

r23jMonica Lewinsky. I - she didnt ’ use her name, ve 

tzr]at that time, she said. “There is someone that I don y;. ‘

frankly, 

kke 

tzslthair behavw. they are hanging around.” Were the terms 

oIcs1srf Page 134 to Page 139 
3235 

Page 140 

Leon Panetta, 1128198 XMIulll 

[I 1 that she use: And ‘ they are spending too much time around 

[zlthe West W-g ” 

I31 Q Thfre y you said - pardon me for interrupting 

[ 4 ~you, but ye sazhet.helr. you mean she? 

i51 .-, 

[61 Q Okay. 

A She ‘ is spending too much time around the West 

IiiW~ng. andAm g;F? F move her.” 

191 

[lOI A And r - I had complete trust in Evelyns ’ judgment. 

[ IllAny time she acted. I trusted her judgment. I wish I had 

I 12 1 more Evelyn Liebermanns ’ working in the White House, because 

rl3lshe was sucfi a tough disciplinarian. If she saw somebody, as 

[ 14 1 I said, who was not dressed correctly she would discipline 

clslthat person. 

I have seen her discipline the press who if they 

!:7”1 had their cameras in the wrong 

[islwhere to place their cameras, s f? 

lace, I rnean,she ‘ told them 

[islthem to move them. 

e would go out there and tell 

I201 

f !?t?y&sted her judgment. and when she told me 

I$ithat I said Tie.” 

Q ‘ All right. She didnt ’ like her behavior, and/or 

I::ishe was hangin around the West Wang too much? 

1251 A Aat is right. 

Page 141 

[II Q 

A 

Did she get more specific than that? 

No, it was basically that, and that, you know, she 

I:;didnt ’ like the appearance that it was creating. 

I41 0 All . ht. 

A 

What kind of an appearance? 

I thin n! just you know, the appearance of someone 

izihan ing around, and gawkmg, and - you know, trying to see 

c7lthe President 

I61 Q All right. Did she complain that - or express 

[9]concem that Monica was trying to be - not only to gawk at 

tlolthe President but to - to be around the President? 

Ill1 A Yeah - I think it was - I mean. her terms was. “I 

ilz jdont ’ like her han in around.” 

I::lQf&e? 

Q Al?&. Did she specifically mention the Oval 

1151 A No, she never mentioned the Oval Office. 

I161 Q 

I 17 1 tryin 

All right. What kind of behavior, other than just 

rlslthe 8 

to - when we say the West Wing, I take It you mean 

i19i 

est Wtno. first floor? 

A -that is correct. 

!:yiother than 

Q What - what - other than that - what behavior 

ha 

rzzland gawking a n? 

ing around the first floor of the West Wing 

the President? 

I231 . A I dont ’ - I dont ’ remember her adding much more 

[241? ht - as I said, 

. . . 

I didnt ’ even recall her using the name 

(2510 the ndrwdual. There was just - it was enough for me 

Page 142 

[ 1 tthat she didnl like this person just hanging around there, 

[zland wanted to move her out, I said, Fme. ‘

131 Q Did she express a security concern? 

I41 A Secu’ concemwouldbeobvious but lcant ’

; : ; re$ef;~r~;~~n$at. But. obviousty, anybody who is 

est Wing without any specitic mission or 

I 7 1 responsibility one has to be concerned about why they are 

relthere. 

191 Q Did {ou - diddou fear Fat - did s@ suggest 

rlolthat she heard an 

I 111 state that she ha dy” 

ng abo any particular - or did she 

heard anything about any particular 

I 1: 1 tncidents i?votvi?g Monica Lewinsky and the President? 

[131 A NO. 

Q Were you concerned - strike that. Did she mention 

i::ithat she had heard that there was a relationship of any kind 

[ 16 ] bebmXi MAOnicaNpwinsky and the President? 

1171 

[181 Q Did she have to say that? Would that have been 

I 191sornething. based upon what she said to you, that wouM have 

tzoibeen an automatic concern to you and Ms. Ltebemann? 

1211 A I - well, again. rt was more the appearance of 

122 I having somebody hanging around there that concerned us. And, 

r23lfor that reason. you know, we would act on it. Because of 

(24 lthe concern about the ap 

1251 Q Okay. P 

arance of somebody doing that. 

Te I us what you mean - tell us what you 

[ 11 mean by - and I know appearance seems like a &ear m - 

t z 1 but tell us exactly what you mean by appearance. 

I31 A 

(4 1 

We!l, let me - let me be dear. Obviously, in 

oing into this positlon as Chief of Staff, 1 was aware of 

[ 5 1 w e - of the rumors and the allegations that involved the 

16 1 President - beginnin 

[7land Paula Jones, % 

as Governor - with Gennifer Flowers 

an , you know, jUSt the general rumors that 

[ 8 1 had surrounded the President. 

I91 And, as a result, we took particular 

[ lolinsure that there was never the appearance o P 

recautions to 

the President 

I 11 Ibeina wdh somebodv. so that it could be misinterpreted. bv 

i 12 jthe eublic or anybodi else. . 

I131 Sq that, on trips. for example, if an acquaintance 

[ 14 Iwanted to dnve with the President we woukl say, “No.” If 

115 1 there was a female acquaintance who wanted to greet the 

[ i 6 ] FresIdent we WOUld Say, NO. ‘ ” And we just took precautions 

[ 17 1 like that because qf. again. the appearance, that we wanted 

[ 181 to protect the Presidents ’ office and pied his integrity. 

Q The - did you ever discuss that with the 

I :z ! President, doing those kind of thinas? 

r21i A Yes. 

1221 Q 

A 

And what would those discussions be? 

I::;lf we said “Look 

I mean the President was always very coo 

ou know we dont ’ want ou 

ratjve. 

Iz51was ah olb friend&at hetiewfrornhis ’ -& &$$” if’ 

Page 144 

[I 1 Governor. we would say, you know what the problem is, it 

rzlcreates the wrono appearance and it shouldnt ’ happen.” And 

I 3 1 he would say, “Fhe?. 

I41 

151 AQ HOekZver resisted. 

I61 Q When a particular issue would come up about 

t7lgreeting somebody, or something like that? 

[81 A Yes. I mean, you know - Barbra Streisand wanted 

191to come in and meet him at a certain place, and we thought it 

~lolwas not appropriate, we would tell him so and - and he would 

[lilagree. -- 

Q 

i ::~questions. 

I realize these are sensitive - very sensitfive 

ifthere is ever anv-time vou warttto take abreak 

il4jf&elfreetoletusknow. - * 

FOREPERSON: 

I : 2 i time for us to take a break. 

Actually, Sol, now would be a good 

1171 MR. WISENBERG: Okay. 

1181 FOREPERSON: Ten minutes. 

IZiexcused? 

MR. WISENBERG: Thank you. May the witness be 

1211 FOREPERSON: Yes. 

(221 ttness excused for brief break.) 

Kiback? 

IY R. WlSENBERG: Are we ready to bring the witness 

(251 JURORS: Yes. 

Page 145 

111 w: ..- TWPanetta;t wdrllblike, to remind 

I 2 1 you once a ain that ou are still under oath. 

131 #in WITFIESS: Thank you. 

141 BY MR. WISENBERG: 

Q And let the record reflect that Mr Panetta has 

! zi reentered and you are the same Mr Leon Pan&a who has been 

17 1 testifying here all day; is that coned? 

I81 A That ~conect. 

Q The - we were talking about this incident whew 

[ :iI Ms. LiebeFanh;;Fzs 

(111 rd 

our Deputy at the time? 

I::;COnect? 

Q Spoke to you about Monica Lewinsky; is that 

1141 A Thatiscorrect. 

I151 Q The - and YOU mentioned that there was an 

rlslappearance roblam- _ 

Ml? WlSENBERG: Let the record refiect that Ms. 

Page 140 to Piie 145 

j 

OlCStarr 
3236 

8% 

__ 

Leon Panetta, 1128198 

Page 146 

I ‘

.-I A That is correct. 

;:I Q Okay. So you had at least seen this person - 

;31 

I41 

$ Ihat isn$h; 

aroun b this bme period; is that correct? 

15; A 

it: Q 

That is righ 

: 7 1 you, correct? 

By the time period when Evelyn Liebermann came to 

:B: A That is correct. 

I91 Q .You mentioned security. and, obviously, I take rt 

: ~olyou mean that rt - it goes without sayrng that that is 

: : I ; automabcally a secunty type problem: IS that correct? 

::21 A 

:13lhave - 

That is correct. You really, you know, should not 

as I said - either staff or interns, or anyone else 

: i 4 1 for that matter, located in the West Wang because of - 

! : s 1 because of securv, but.also because I think rt then 

! 16 1 undermrnes drsup me wrth regards to the rest of the staff. 

Q You sa 

Iiiigawking. either or bot X 

located in the West Wing, or located in. 

A both. 

? 

1191 

[ZOI Q Because a ain. you diinY want just people - 

1211 A 

!221 Q 

I didnt ’ -I ‘ didnt ’ want people located there. 

Okay. But there was -was there any particular 

;231concern with this individual, that you were worried for 

'24 1 the - any articulation by Ms. Liebermann. “Im ’ worded that 

izslshe might harm the President.” Was there any articulation - 

Page 149 

( 11 West Wing and gawking - was there any other pman who f+qs. 

12 ] Liebermann or anyone else came to 

[ 31 appearance issue that you have iden 

ou about on this 

r- rfied? 

141 Is my auestion clear? 

i5i 

161 

; A$other ‘ than this one instance? 

A 

/iishe did not - you know, if someone, for example wanted to 

Well, I mean, there were times when she would say 

[ 9 1 

[ION ! 

et on Air Force One that she did not want that person on Air 

orce One. And, I mean I can remember some instances like 

[ 11 lthat. where she - 

I121 Q Okay. 

A -would say that. and - you know - and that - 

i::;and I would-if that 

R” 

rson 

[ IS 1 responsibility I woul 

didnt ’ have a policy 

- I would agree with her. 

I161 Q Okay. Lets ’ - lets ’ - so she wouM - there was 

[ 17 1 at least - there were more than - there was more than the 

[ 1 B 1 Lewinsky occasion, in a global sense? 

1191 A That is correct. 

Page 147 

III A No. 

I21 Q Okay. Now again, she was a staffer by this time. 

13jshe was not a - she was not an Intern. correct? 

141 A That is what I understand now to be the situation. 

Q And how often do you recall seein her Monica 

i zi Lewinsky? Lets ’ take - you have told us you - s#ike ihat. 

(7 1 While we are on this topc. let me ask you how many other 

I 8 1 instances when you worked at the White House did you have 

i 91 somebody approach youin the way that Ms. Liibennann did, and 

::~~inc!iiidual? 

! lo 1 sa there is a problem with a particular - a particular 

ii21 A Had Ms. Liebermann - Ms. Liibermann approached me 

::3jon others - 

. 

(141 Q Okay. 

- by that in which she would say there is - you 

Iiziknow. “There is a robkm with this indiiual ” Or “There 

[ 17 1 is a problet with that prson ” “This person is notdoing 

I 1 EI 1 *err job. 

t191wr - 

Or. “I dont ’ tke the way that person looks.’ 

I201 Q Okay. 

(211 A ShewouldI221 Q But Im ’ talking about the particular - 

i::iyou know. 

A Shewasagood-shewasagoodfintsergeant. 

1251 (Laughter.) 

Page 148 

Q But Im ’ talking about the partiilar issue that you 

iii have identiir, the appearance, the appearance issue you 

I 3 1 have talked about. 

i : 1 any other. 

A This -this particular instance I dont ’ recall 

In other words, when? somebody was just hanging 

I 6 1 around the West Win 

Q All rig& But I want to be as precise as I can. 

i 2: IlThere is only one instance 

I $1 hanging around the West IrJ 

ou remember involving somebody 

rng,, correct? Other than Monica. 

t 1 o I But - but my precise question rs - well, first of all let 

:;lrme stop there. 

I”] Is that - is that correct? 

iIZ;if 

A To the best of my recolleciion - I mean, I - 

- I - the best I can remember is that - I mean I recall 

I I 5 I this one instance. but I dont ’ want to say that - you know, 

! 16 I R may Well have been that Ms. Lk?&rmann came to me and may 

I :T 1 have. referred to some others that - you know, in terms of 

I I B I walking through the West Wktg. 

:19lmuch -but thus is the one I clea 

or not, you know, having too 

1201 Q Okay. Now, a slg ??msmbe tly d&m&question. Was 

I 2 1 I there any other person you remember - and by definition it 

r221would be female - given the roblem 

123 lappearance problem about t R ilI 

ou have identified, the 

e Pres ent, I think you 

~24 ~menboned Gennifer Flowers - was there any other person - 

I 2s I irrespective of whether or not they were hanging around the 

Page 150 

That is correct. 

S 

Page 151 

tiiitisdiffiarltformetopinanu~r,brititwas-- ‘

l2lknow-itwasafewtlmes.andIdonrthinkitwasmore 

rslthan ten. 

Q Okay. Now 

+leissueofpeoplewho wo$J&~~$9!$~;o~alYY~ - 

ts]inVle-PvecallcditUleOEOB;isthatconed? T&Old 

17 1 Executive Ofhcs Building? 

181 A 

Q 

Right, that is corred, 

!illDepart.ment? 

The - is that the butlding that used to be the War 

111 A Tbatiscomsct. Still- - - 

il21 0 Years ago? 

A 

IZlwest of the West Wrna. 

ft is the old building located, I guess, to the 

ilSi Q okay.-Lets ’ confine it rtght now - lets ’

I 16jabout OEOB for a second - after Ive ’ had you tell us wha 

117)~-aandjusttalkabouttheWhiteHousc. 

yt . L 

I251 Again, just on the issue of empbyees or people - .* _ 

OlCStZllT Page 146 to Page 151 
3237 

BSA Leon Panetta, ll28196 _-_l_____~-I___ _..- ----. XuAX(z8.) 

Page 152 

f 11 ou know, employees rn the White House on a regular basis. 

12 I 1G ot an event, not somethin 

[ 3)to somebody who was 9 

related to an event. as opposed 

regu arty In the White House. 

id1 Is that ctear? 

I51 A Yeah. 

L81 Cl Okay 

17, A I believe so. 

Izll2 2% or& that I think she worked in the 

(::;Democratic Conventio:, Haroidlckes. ’ But beyond that I dont ’

(24 1 recall all of her specific assignments. 

I251 Q And she is an old friend of the President: is that 

Page 155 

; 1: personnel action there cold be re 

i-1 Q 

~cussiom 

I dont ’ mean to be rghly technical, but 

for thati 

ou said 

) 3: taking action like that, do you mean any time you trans er 

14 ;anybody. or actron like she topk In the - spetically in 

; 5 j the appeafnce type of situation. the Monrca type s&ration? 

(6: No, It was more than that. I mean, any trme - any 

r - ; time Evelyn acted. ou know, wrth r 

: B 1 employee she usua 7. ly rnformed me “3. o 8. to make sure that I 

atis to dis~plining an 

r 8 1 would - you know, I was aware of rt and. obviously, I would 

[ : o 1 support her. 

Ill ’ Q There have been reports in the - Jet me 

[ :Z 1 strike that. The - was there any - after this decision was 

1 I 3 1 made - well, after this conveoation was had with Ms. 

I 14 1 Liibermann. YOU assumed that she would simotv take care of 

ilsjthe problem?- . * 

1161 A 

AQ 

That is right. 

1171 flPl 

kz she tell you exactly what she wanted to do? 

L-“‘ 

Q 

IZitJ7e employee? 

&d she indicate whether she woukt fire or transfer 

I211 A I dont ’ recall. She just basiiltv said. “Im ’

r22 jmoving her out.” 

1231 Q All right. We are talking about Monica Lewinsky? 

[241 _ A Uh-huh. 

1251 Q Is that right? 

Page 163 

[IlcOmfct? 

t21 A That is my understandin 

(31 Q Going back many years. 4 

I41 A That rscorrect. 

Q Okay. Did you speak to - well, what did you do 

Iilafter Ms. Liebermann brought thus to your attention? 

i7i 

I81 A 

191 Q 

It - we woukf just take precautions - 

Well, I am now talking about the particular 

A 

Q %t Ms. Lewinsky? 

_-.______ .~__._. __ - 

Page 164 

~~~~procedure to make sure that, you know, I was aware of the 

( 19 1 action she was taki 

Q Wou 3. she tell you about any empto ee workktg in 

(:iithe White House who woutd be transferred or fired 7 

; 

i::iaction 

A Yeah she - I mean she woutd - Jfshe was &king 

like that I think. as a good D& 

(24 I her responsibility to tet me know tha P 

uty, she knew it was 

i 

personnel. you know, 

rzsjmay be moved. Because. in the end, any time you take 

Page 156 

t11 A Yeah. 

i:iwhat. if anQ ~I~~~? ‘

- after she was moved out, what did - 

I41 z I dont ’ recall an fallout. 

Q Okay. 

IZilbeen moved?. 

Did any g ody ever ask you, Why has Monica 

171 A No. 

Q After Ms. Liebennann had brought this to your 

~~~attention. did you discuss it at all with tha Prestdent? 

I101 A I did not. 

Q Did the President ever ask you, dire&y or 

f ~:~indimctty. why ‘ has Monica Lewinsky been moved?” 

1131 A No not that I recall. 

0 Dii the President after she was moved, and - are 

t : : i you aware where she was mov&? 

1161 A 

Q 

No, I wasnt ’

Okay. So you wouldnt ’ be aware that she - before 

i : i ~she went to the Penta on she m’ 

rlv]Patsy Thomasson, in 0 e OEOB B 

ht have gone to work for 

1201 A I-Imnotawareofthat ’

Q okay. Did Ms. Liebemnn say anything about 

I~~~denyinghera-,den 

123)Was moved 

Monica U&sky aazss after she 

124lwestwi 3 

accesStO--fe v* SJUStSaythefintffIXXofthe 

t251 n% I dont ’ remember that. You know, that she said 

e 

Page 157 

take appropriate measures to make &e that that 

ou - I asked tha question kind of 

e West wing, would that - 

I dont ’ recall her speakino 8s to what partiilar i~sistep shewas goi totake. . - ’ 

Q d knowing Evelyn Liekrmann and knowing whaf yo 

~~76l)expeued of her, and what she expected of you, are ‘ you saying 

I 18 Ithat you mxrkf have expeded her to make sure that this 

rson simpty wouklflY4iR&3:-wayi?a&4f+tHtewkik, 

I::; Fis ouse? 

-. 

1211 

A Q rh*DTt You~n~~thatyou~~go~a-~~u~. 

!z$&pen that an intern couid go straight fmm the internship 

124 Jinto a White House staff .ob rf they had -were 

t25jextraordinariJy responsrb 4 and had done a good job. Do you .i _ 

-_ .~. - _ -.---- 

Page 152 to Page 157 OICStif7 
3238 

BSA Leon Panetta, 1128198 

_ ___. ~____ ~~ XMAX(27) ____~ 

Page 158 

c :. recall that? 

[2: A Yes. 

0 

i :; Lewinsky was considered to have done when she was an intern? 

Do you have any idea how good of a job Monrca 

(5‘ A Not realty. I mean I - she - she did a pretty 

[ 6;good job, as I recall, you know, handlin 

I7:not - rt wasnt ’ easy particularlv durina a 

the phones. It is 

t e shutdown 

[II 

I1 ’

17, 

Page 161 

A Tha! is - 

0 Is that correct? 

A - correct. ,-1 

Q 

I”siword gawking. 

Okay. Would YOU we us your interpretation of the 

A 

i76jand. you know, in a way looking around. trying to, you know, 

I think just. YOU know. krnd of standing around 

[ 8 1 catch somebod s ‘ eye. 

!91 Q 

A 

Trying to catch somebodys ’ eye? 

iiy;definition - (lau hter). 

That IS right.. There has got to be a dictionary 

I121 Q 2nd - pardon me just a minute. 

I131 A Sure. 

(141 Bnef pause.) 

i:iiyou know’ 

Lets ’

I :z;said that you first me 9 Ms. Lewinsky during the January 1996 

o back for just a second and talk about you 

jl7)govemment shutdown; is that correct? 

A That was - that was m first recollection of - 

- it is my only recoltection o 7 her. 

1201 Q That is your only recollection of her? 

[211 A Yeah. I mean, was - 

j22l AQ Okay. 

-when she -when she wodusd there in the office. 

I::;As.l said, I think I did see her periodically if I was 

jzslwaking. you know.inthe comcfors,lmight seeber. But-1 

[ 9 : because we had alirge number of dlls comin 

:9:she did that, you know. with, I think, pretty g oo% 

in. So she - 

[ i o I capability. 

(11: But beyond that, I ust ‘ - I did not follow the 

I 1: J interns that closely to - you I, 

[ 13!capabilities. 

now - to really view their 

Q Nothing that you recall as being standout about her 

IKiintern performance? 

1161 A That is correct. 

1171 Q If she had been caught gawki? when she was an 

[I 8 1 intern. would you have allowed her o have a s aff job rn 

r1910lA? 

1201 A No. 

I211 Q What do you know about Jot - a lady known as 

[ 22 1 Jocelyn Jolley? 

[231 A 

Does that ring a bell? 

No, it doesnt. ’

0 

I::isupervisor of Ms. Lewinsky in the Oftice of Legislabve 

Do you know whether or not she might have been the 

Page 159 

[I IAffairs? 

[21 A I do not know that. 

Q Do you know anything about any other individual 

I:ibeing transferred out at the same time that Monica Lewinsky 

j5)was. 

[61 A Not that I recall. 

Q 

/z i because of not 

Do you recall anybody being disciplined in any way 

have 

191 A No, I rz ont. ’

controlled Ms. Lewinsky? 

j101 Q You have heard about the - have you heard some of 

[ 111 the reports that have been going out in the media 4n the last 

(12 )few days, about an incident in a movie theaten 

1131 A I have heard those reports. 

II41 Q In fact, there have been, I believe, denials issued 

1151at least on your behalf, and Ms. Liebermanns ’ behalf, by the 

[ i 6 1 White House; is that correct? 

1171 A That is correct. We were - we were asked if that 

I 19jwas true, and we indicated that was not true. 

Q And I believe the stories are that - I think 

i:iithere are many versions of the story by now but I think the 

12 1) story is that some kind of an Aide, somewh&e or Secret 

t22jService Agent or Aide, saw the President and Ms. Lewinsky 

t241a~ 8 

tz3je a 

t 

ed In intimate behavior, or intimate sexual behavior, 

at somehow it got reported to you and/or Ms. 

r25)Lisbennann. 

Page 160 

I11 Is that more or Lws how you heard it? 

I.71 A That is what I have heard. 

131 Q Okay. 

I41 A In terms of the rumor. 

I51 Q And as it applies to you, is it - is that true in 

[ 6 1 any way, shape or fomr? 

(71 A 

I 8 I agent had 

that is not true. I can assure you if - if an 

told me, or I had been informed of an instance like 

[ 9 Ithat. that I would not only remember it but I would take it 

I 1 o I up with the President. 

1111 .Q 

I 1 z I to say until 

Okay. And you dklnt ’ - you didnt ’ - is it safe 

d 

ou 

I 13 1 never hea 

heard the rumor over the last few days you 

a rumor to such effect? 

I141 A That is correct. 

Q You didn? hear lt firsthand, secondhand. third 

i ::1hand, ’ eigh~senthohand - 

1171 

I181 -iithatcorrect? 

1191 2 No. 

I201 Q No, it is correct that ou didnt ’ hear it? 

I211 A No, lt is correct that r did not hear that. 

1221 Q All right. The incident-the only incident you 

I 2 3 I recatl with respect to Monica Lewins 

t24 Icoming to you on this appearance pro % 

is Evelyn Liibermann 

[ 2 5 1 problem? 

lem. thrs gawking 

Page 162 

111- I - it was not that often. 

121 

131 

AQ 

But that was my only - 

Okay. And t believe you sard - 

- recollecbon - 

I41 Q - you saw her - recollection? You said that 

t5)was - 

161 A Yeah, that was - 

j71 - your recollection? 

181 AQ 

Q 

- m only recollection 

191 

rioi 

I cu?vou off. vour last Dart of - 

Alms6rry.~~ ’ ’ 

Q So - and I beliive you testified you saw her, she 

1:: !was there for a period of a couple of days during the 

j13)shutdown mannin phones; islhat correct? 

[I41 A Th& ripht. 

1151 0 

r16lour mao? 

And tha would have been in Reception Area 2, on 

ii7j ’ A That is correct. There are a number of desks in 

r191Reception Area 2. I dont ’ want to - if I start drawi 

tl9)there.wonY be an 

t201(ust “9h ?’ . 

hrng left of the Reception Area 7 _ w 

~21 J here 

ht outside he door Into Room 111 there ls a desk 

at normally ls the indivkfual who answers phone, and 

r22)that would have been at the approxknate locat& where she 

t23)was located. 

1241 Q Did you know anything about a - strike that 

I251 After this occasion. you sard you saw her between 

At 

Page 163 

tl)the tlrne that - lets ’ -ietstry% ’ gRThefimeframe. 

t2)You said you .saw.her a few more times after the budget 

t3)shutdown penod. in the corridors, as you were walking 

rctthrough the - 

151 

161 “0 That is right. 

A 

-walkways, and hallways; is that correct? 

t71 That ls correct. 

Q 

iiiwe were talkin 

Now that would be generally in this West Wrng area 

A 

about today? 

I:f$~as walkin 

%es I - I do believe thete was one time when I 

in the basement of the private residence where 

[ 12 1 she was wa 9. kn thro h that area. 

Q 

I::&zsldence? 

8kay.h what is the basement of the private 

;::;i& 

A I call it the basement I mean its ’ - you know, 

- its ’ the lowest - its ’ the lower level of the 

%%e EaskWin& _ _klr*a_hu~~ 

’ ate residence. It is usually the halkvay that leads you 

~~$mderneath the We!t Wing? 

A I think that s right, it is ground level. 

1227 0 Okav. And - 

- 

otcstarr Page 168 to Page 163 
3239 

dSA Leon Panetta. 1128198 

Page 164 

r6lthiS is at around Level. as I recall. 

i+$oaInd ie$L _ _ I_ . _ 

I ne rim noor 15-t 

A” Thatisaxmct. 

Q. okay. 

A ThisfirStfloorkat roundb~al. kd,I 

ii;imean - yt% know, vou-ifvwwa Bk outthenoJtha& 

Page 165 

111 

t2J : No. 

A tio?ryti%?f was - I was rush@ around, 8s 

I~~in0mwJyusadw*do. i_aiUIcr . *pk”ow.y- 

[5JgOi~tOaneVWltOrQOi~tO8bna Jl& <fWSS- Was 

[6JWhlrl9 somewhen. 

171 Q How unusual woukl that be, to see a s@ffer. Office 

[ 8 1 of Legislative Affairs staffer headi towards tha - 

I 9 J p8rticulariy a bw bvel staffer. hea ?I 

I 10 iresidence ama? 

tng towards tha 

I i 5 f fsnY - it k&t that. unusual. 

Q 

I:~jyoufindaunusullNIanywayatthe 

[19~8bOUtit. Orbd you find it - well,g,~r#~y, did 

IZLoridng 

A We~,ifyhewasworking-lmean,tfshewas 

in the 

L”p 

tsbtwe of6ca and was tmnsii for 

masontha wouldnothavebeenthatunusual I’ 

j~~j~%ied to mall it now, because, you knaw, it can8 ct dc to 

Q tsitoneofthosethingsthatwhenahterevent 

$!.i happens that later went causes you to mcall earlier events? 

paSe 166 

111 

::1 

AbtccerMy does. 

6 - 

I41 A i%&iiIy does 

Q Aretheman oihertikethsfthat 

I~~othereventsyauhavemca &d? Youh8vet8~%- 

[?JyOU~id~~hefOfewtln?+ktheconid~,u~hPW 

JeJmenttcxred.ea~ttunthatwhanyou~~~~the 

191~wes. my ot@er - any other klstpnces, speafic btstances 

(101 atcometornmd? 

Ill1 

1121 

$ N&Th8t-thatmalty- 

* I::; 

A -Eta most I can mmamber 

Q -Gmanytimes without-w&outrdaenceto 

(lSJr8rIWllbe~Ospeclhcincident:hOWrJl8nytimesthat 

rl6Jmcall you - do 

1171 

A ~Bm~$b&~ ~$$o~&< 

; :;lphanes? 

9 Okky. That~inaddiitohermankgofthe ’

1201 A Thatiscorre& 

1211 

1221 

2 gt f.. g5ent on the way to the maidence? 

I231 Q okay. soifyou8ddtwoorthmetothosatwo. 

l24Jmaybefourorfivebmes? 

l2Sl A t~~~at~-~t~~~ir. Asbcstas 

Page 167 

JlJl can rec43llect it. 

Q Dii you aver sac her in the White Housg after MS. 

j:l~iabermenntoldyou~mrmovingherwlthatismoving 

I 4 I Monica Lewinskv out? isi A hro. 

f~~totheWestWnoama-letmestrikathat. 

Cl Ifyoutudfoundoutthatshewasangul?rvisitor 

P8ge 168 

t:!hercwt bthataf8irsWemaM * 

Q The-YmakasnosanSeinMrnsoftransferring 

lOUMZUV8lW-f 

iEVVtR4ESSz tm&y. ’ YouamtaNdngaboutoff . . ‘

REPERSON: Yes. To take a shortan that way, Q ,, 

_._-- - __ _ __ 

Page 164 to Page 169 
3240 

as* --. 

Page 170 

Leon Panetta, ~128l98 .-____I_ 

Page 173 

li;schedulin 

Normally, that discussion usuaj~y involve13 Iplace. an i 

YOU know. we knew he was going to a 

wanted t0 take 

ar&rar 

f P 1 appearance, and we woul 8, 

recautions, again rega rdp rng the 

rarse those issues WA htm. 

151 As to other situations, I mean if someone. for 

!4lexample, wanted to see him and 

illyoU could - 

[?j THE WITNESS: No. no 

(31 FOREPERSON: - bring papers back - 

141 THE WITNESS: No. no, no. because I - I really - 

~511 conttdered that to be the private quarters of the President 

r4lof the United States, and I was not goin 

r7 1 there. I would o around throu h the ot a 

to go barging rn 

er end. 

(81 FORgPERSON: 8kay. Thank you. That is all. 

BY MR. WISENBERG: 

only exception to that was if we were briefing, 

r~,)instead of the Oval Office we were briefing in the dining 

Page 171 

[I 1 room then we woukt use that access off of Walkway 2, to bring 

( 2 1 people into the dining room. But that was - that was 

r31deared by me. 

Q Dii you ever hear any rumor - any rumor of any 

I :i kind before this - this event broke a few days ago, any 

~6 1 rumor of any kind about the President and Monica Lewinsky 

r 7 I beii involved in a relationship0 isi - A 

Q 

No, I have not.’ 

You said that if you had - in response to some of 

[ :ilour questions, some of my questions - in&din one recent 

I I 11 one about what would you have done if you ha c? found out the 

p” 

rson had - had been allowed in 9fteen to twenty times to 

1 iii he West Wing - you would have discussed it with the 

114 1 Prasident. 

I151 Do you recall answering that - 

A No, Im ’ sorry. tf that -_ what.that was referring 

i :t\to was if soQmeo;; TV& seen the Preskfent rn the theater - 

I151 

[I91 A- id some - kind of - 

1201 

A0 

- theater incident. Okay. 

- in some kind of ccmpromising situation and had 

i::iinformed me of that I wouM certainly not on rememberthat ’

[ 2 3 1 I would have gone to the President and sa it1241 Q Thats ’ right, I stand coneded. As a matter of 

rssjfaa I think your answer was to the -to the question about 

._-__. - 

Page 172 

I I @teen to twenty tiis you woutd have gone to Ms. Liibermann 

[ 2 1 and said, Whars 

131 A Tha 9 is rght. 

oing on?” 

I41 Q Oka . 

[51 A Tha Y s . ht. 

As an initial step? 

Q And It~eitifshehadsaidsomethingtothe 

i ~~effect of. “The Pre&ent wants it that way,’ you then would 

{ 8 g have spoken to the President? 

I91 A That is correct. 

~:~~incident 

Q The - did you -getting back to the rumor 

the movie - movre theater rumor that we have been 

rlz@eari 

% 

*about in the press, dii you ever have any - any - 

f13fother an-letmeseeiflcanaskthisinahaffway 

tl4tliiratewa 

how 

1 ::lwith the President, about the appearance issue. 

many times did you have that v of discussion 

[ 17 1 have mentioned - bt me just ask you that way. 

I mean, you 

118 1 times did you have the ap 

How many 

I 19 1 President, related on - p” 

arance type discussion with the 

tzotabout or saw? 

re atect to an mcident you heard 

As opposed to you earlier talked about somebody 

~:~~going on a trip and you dont ’ want them on. Lets ’ just talk 

g 2 3 1 about me issue of based on any incident you saw or heard 

g z 4 1 about. or any rumor you heard about. how many discussions 

12 5 1 with the President? 

1251 - But it wasnt ’ that much. It reaffymnnt. ’

Page I74 

ill Q 

A 

About how many times woukf that happen? 

I21 I dont ’ know, maybe a couple of times. Two or 

t3tthree times. Not that much. 

Q All right. Any particular incidents that stand out 

i : 1 in your mind among those two or three? 

A No. I mean if - if I had heard for example on a 

!76:trip. that he had 

I 8 1 you know, while ,x 

ou know, gone in a car with somebody and, 

was - it was perfectly innocent it 

tstcreated a certain impression, then I might raise it with him. 

[lolAnd that WOUM be the kind of thing I mrght raise with him. 

Q Again I want - I just want to make sure - I know 

i::!it is a sensitive question do I understand 

t13rwere two or three occasions to the best 

ou to say there 

#m 

[ 14 lwhere you approached the President afler learning about an 

t151event. on this a annce issue? 

A &inla 

!:761- that woutd have been the case. It wasnt ’

m - as best as 1 can recall, I think that 

tlelwasnt ’ that much. On the other hand, if some 

-&oukrww, t 

[ 191 bra 

mrg was 

~20~~~ President. 

M to me that would concern me I woukl usual& raise tt 

!::jlrelatlonship and I never f&tat 

Or if I - he and I had ~retty.stmightforward 

to mrse those k&Is of 

rzlrl~swswithh~.~lthouahtthevwere-thevwerea 

i~rjconcem. _ * 

1251 Q As a general mattet? 

Ill 

121 

I31 

i41 Q Any concern you had? 

151 A Thats ’ right. 

Q On the two or three occasions that you remember, do 

i76iyou remember anythin 

rejwhenyou~ 

notable about the Presidents ’ response, 

htrtto rm? 

Uc,-h~~eneml~*ou.beve?-1rran.r 

f$~would say ?oure ’ right. You know it shouMn have 

In 1 happened:” Or. I mean he - he neier resistedthe - you 

t 12 1 know. if t made that attttm, he woukt always be receptiie 

t131to it. 

I141 0 He never said the uivalent of Back ‘ off”? 

A No. He never said “SB ack off irs nons of your 

~~:~busim?ss.~ Or, bbh. btah. blah. f& always &aid You are . 

I 171 ’ 

Tt 

ht.’ Or, you know. “Just we have to be -; you know. he 

[ 18 IS ouktnt ’ do that. that kind of thing. 

Q What were - to me best of ynnutrecdledro 

IZlrna best of your recoftecbi the best of your specific 

. n-.k?_ 

r21~scollecbon. tell us about th&e two or three tll. 

A 

IZjmean. to remember the specifics. It really IS. I mean I 

(Chuckling.) That - it is very diilt to - I 

tzctthink you know, there may hav 

fzsjmay have.ridden in a car with 

ne time when’ I think he 

aandwejust -: 

._~ _ .------ ----_ -- -._-_ 

OlC-!%rr Page 170 fo Page 175 
3241 

_-. 19. Leon Panetta, 1128198 

Page 176 Page 179 

:;were concerned about the ap 

t” 

arance of that. 

-i And the only other hrng that we took - we wanted 

i 3; to make sure that he did not sta 

.i :San Diego. To make sure that t K at would not happen, and it 

at the Lawrence house, in 

; :! didnt ’ happen. 

-si rumor you 

Cl And that was based on some - was that based on any 

:c; 

have heard? 

A It wasnt ’ based on a rumor, it was ust that the 

: ii President of the United States, we felt, ought not 1 o be 

::; ;stayin at - at you know, a womans ’ house. I belteve this 

. . . : _ _ lwas a fi er the death of her husband. 

“?I Q Okay. Now that was an - that would be one of 

i:;lthose future scheduling incidences? 

::41 

i:51. Aa 

; 16 1 it happened? 

TThhaetii/BPllll)inciident would have been after 

Li71 

$ 

i:ilafter the fa$ liEot at? 

lD?$?r~%l~ %rgd incidences 

[201 

Q Any other memories? A ain. Im ’ t in to confine 

is: Imvself to the occasions where you wou 5 have tal 2 e j-talked 

[lOi Q One, and who was that? 

111: A Well, there were two when I was there. One wss 

[u]Howard - 

I131 Q Pastor7 

I::~actuall 

- Pastor. Well Howard Pastor was there - 

[ 161 Staff. 

I think he had left by the time I became Chief of 

ut I had dealt with him as Director of OMB. 

Then came Pat Griffin and Pat Griffin worked me 

i :i; both as when I was Director of &lB as well as Chief of Staff. 

[ 19tAnd then John Hilley. 

Q All right. Do you know - do you recall when 

I:i;Hilley took over from Grifftn. rou hty? 

I221 A I believe it would 3, ave been some time in eartv 

Page 177 

A 

ii;what the s 

I - it is difficult for me to recall you know, 

ctfics of that would have been. But thats ’ - 

i;lthose are phe ” - those are the only ones that come to mind. 

i 4 1 But I know, you know, there are others but I cant ’ tell you 

[ 5lwhat exact1 

I61 Qy 

the situation was. 

Okay. Did the -who - how did you find out about 

- do you recall who would come to you on - again on these 

iiitwo or three instances, how you would find out. the past 

[ 91 incidences? Do ou recall who would have told you? 

LIOI A Oi it could have been you know any-any Aide, 

r I I 1or - nonnallv it - h miaht well have been the De&v who 

ii; iwas on a paiticular trif?. 

_ 

Q Okay. Did the First Lady ever speak to you, 

i i: jdirectly or jndirectly. about any of these past incidences? 

I?51 A NO. 

1161 Q About any of these scheduling type incidences? 

[I71 A No. 

0 Do you know if Monica Lewinsky got any special 

I ::I treatment when she was an intern? That is to say. was she 

tzoltreated better than the other interns? 

Not that Im ’ aware. 

- 

Page 178 

i 11 revious answers would be the transfer from internship to 

12, 6 LA. rn the sense that I believe ou have told us that would 

r31~picatly be for a -thatwasnot&pi(;al,andifttwas 

t 4 1 one rt would be for a standout job; IS that coned? 

151 A I - I think that is correct. 

I61 THE WITNESS: Is this indicative of something? 

171 

ti9fe2 R IS NBERG. 

i :; kind of jumped out of my order and so Im ’ a 

Pardon me ust ‘ a_mpbte. ’ We have 

b le to 

c 10 1 sure to everybodys ’ relief Im ’ going to be able to skip a lot 

f I 7 I of auestions. 

at do you know - what do you know about Linda 

I ii ;Tripp? Did you know a woman by the name of Linda Tripp? 

t151 A I am not familiar with Linda Tri 

1161 Q You have heard about her in &s 

p. 

last week or so? 

I171 A Obviously, I have heard about her in the news. But 

118 1 I- I tried to see if I. you know, even remembered her, and 

t 19 j I do not remember her. 

0 Office of Legislative Affairs, is that an office 

I:ilthat typically you would have had a real interest in, in the 

t22tsense of the day-today interest in? 

A I m not uite sure how L 

15:1broken down between t, ‘tf? 

islative Affairs is 

e East Wrng o ice and the West Wing 

[25)offb% The East Wing office may very welt be involved with 

1231%. 

IZZ;roughfy? 

Q The - right around the time of the shutdown, 

Page 180 

A Yeah. It - tt may have been - I - approximatety 

Ill1 A JUROR: An hour. 

I121 FOREPERSON: An hour. Its ’ break time. 

MR. WISENBERG: 

I::ilets ’ take a break. 

Canwe ~ietsbreak. ’ -Aitright. 

ilsj 

I161 

1171 

1181 

We have a quorum. 

: Let the record reflect that we have 

il9ia quorum. 

1201 FOREPERSON: Mr. Panetta you are still under oath. 

I211 THE WITNESS: I understand. 

MR. WtSENBERG: 

I::ihe is still under oath. 

The wttness has been reminded that 

1241 BY MR. WISENBERG: 

I251 Q You are the same Leon Panetta that has been here 

u” 

Page 181 

tlltesbfying all da ? 

I21 A {es I am 

0 And it is &nceivabM that some of these final 

!:lquestions YOU might have been asked before. Maybe several 

~sjliours ago.- - 

I61 

- 6La”Ver.) he - so let me ask you as quick1 

iildo you ever recall seeing Monica Lewins X 

as I keow how. 

,;~;~rnt-&the~~~e~~ were Chref of SM~$e&%?.%nL 

The area that you have identified as the - on the 

.--, 

1201 A *Yes. 

I211 Q lndudin 

[22lbe opened out int? by t # 

the portion of Walkway No. 1, that woufd 

pse -those areas. Do you 

t231understan~wh~;~m saying? 

1241 

= I251 Q Do you ever recall seeing - you satd you never 

Page 176 to Page 181 OlCStarr 

- 
3242 

Leon Panetta, u28/98 

Page la2 

[ 11 recall seeing Monica Lewinsky with the President did you 

I .-. 7 lever see. to vour recollection. Monica Lewrnsky in any of 

t 3 1 those area;? 

!4: I - I dont ’ remember her - seeing her in any of 

i 5 1 those walkway areas. 

0 Okay. Do you remember a specific room, other - or 

176; hallway other than what you testified to, where you would 

[a 1 have seen her? Other than what you have already testified 

!91to. 

A There, and its possible in Walkway 3. that - that 

I::imight have been In another lace where I might have run into 

~i~~~$-‘“b~he& ’ 

rha s in the - in w at I call the Basement of 

i;4jwell. 

hate House. That - that is possible, as 

1151. Q Now is that different from the other basement 

116 1 rncrdent you have talked about, the - 

A 

I :i ;(indicating 

Yes. That-that would be in the basement here 

h 

of the West Wrng. 

All right. Where you have said the Mess - the 

I :z; Mess is and some - 

I211 Here is tha Mess (indicating), thats ’ right. 

(221 

; 

other thongs? Okay. 

Let me ask you to help us resolve something. Where 

I$:;- you have talked about the Secret Service person posted at 

tz5lDesk No. 1. 

Page la3 

[II A Yes. 

0 We have got some reason to believe that there might 

IGibe -.well, let me just ask it this way. Is there a Secret 

t 4 1 Service agent, or agents posted there in this Walkway No. 2 

[starea? 

[61 A Walkway No. 2? 

171 0 W.K.” yeah. 

A Yes. Normally there are agents that are located in 

i i; the Walkway 2 area. 

1101 0 

A 

Okay. Do you recall what - 

And these are what - you know, the -what I woukt 

i :: i call the - I mean the Presidents Secret Service detail, as 

113 1 opposed to_ the &form detail. 

Page 184 

Q Okay. The -were they typical 

I: ;mean either, you know, standing, sitting, what 3; 

posted - and I 

f 3 l Reception;reaN;T 

ave you - in 

I41 

(51 0 Nancy Hemreichs ’ office? 

161 A No. 

Ll ’ 0 The Oval Office? 

is1 A No. 

I91 Q Hall l? 

I101 A No. 

1111 .--. Q The Study? 

I121 A No. - 

Q 

[ ::iCabinet rneetin 

The Cabinet Room, other than when there was a 

? 

A ?I o. The only other place I recollect the presence 

I :,) ‘ of agents would have been rn the colonnade area that - what 

[ 17 1 Ihave described as kind of a porch outside the Oval Oflice. 

I181 

119, 2 .--. ?&he there was an agent who was located in 

tzojthat area. 

1211 Q Oka How about the porch - okay, the porch - 

I221 fy - 

(231 

$ ;c~~it the porch. 

(241 A It is that - it is that area as you exit the Oval 

[ ~5 1 OfTice through the - 

Ia: Q 

!?I A 

13: 

; 4 jdining rooz? 

(5,-. ‘ A 

[sIthere. 

:! ‘

:!I1 2 

! 31 believe so. 

[IO]. __ .P 

Three ocloa ’ door? 

Thats ’ ri ht. “rough the door to the colonnade. 

Okay. 4t nd cd I ask you about the Oval Office 

No, you didrt but there is no agent stationed 

How about Patro l? 

Not that Im ’ - not that Im ’ aware of. I dont ’

What,!s th_ls t:ng that looks like at attache case 

[ pi 1 nanate juttrng out or me Xucy ’ 

1121 A I dont ’ know wnat the hell that is. 

1131 

[I41 f"%%~ remerrzrer that. 

I:z;that. or - 

0 Is there any fund of a bay window, or anything like 

A No. No, I mean there are hedges -there are a 

I :i i number of hedges and trees in that area there 

119 1 the patio off my office from the Oval office 

that separate 

aiio, and - 

t20jyou know there may well be. 

tzl jwell be an air condiboning undbr somethin~that is there 

ou know - t ere could very 

t221above ground. But I have never paid that much attention to 

[23lit. 

1241 

[251 - 

I dont ’ know what that represents. 

Q Whenthe Presiden IS rnthe0vat Officethe Oval 

Page la6 

iei d catch both of those. 

Q But it is safe to say that as he realty starts 

r:ziroaming around they are going to - outside of the areas I 

[ 1 I 1 have des’ nated they are going to follow him? 

I121 % That IS correct 

0 

I::!to be either in the Cabinet Room or rioht outside o 117 

So whentiera ‘ is aCabinet rneetin~ they are going 

I--, 

[151 A That is right. - 

I161 Q Do you remember which? 

i :i! is meeting A If thei. 

- if they are in the - if the President 

in the Ca rnet Room nonally they will be posted, 

t 19 1 you know, in the colonnade area - you will see some in the 

tzllteadingtotheCabinetRoomc%ofthe%~%eNdoqqr. 

tzolcolonnade area and there ma be one 

Q The - were you surprised to hear that Vernon 

I::; Jordan had - and Im ’ talking about his public statement now, 

I::r~~~~~~.~~~~cuy~~rm that Vemon John 

III 

171 

G 

Page 187 

2 Yes. 

Can vau tell us whv? 

i &$-I%%& I z I think you know Vernon - 

~:~Vernon Jordan is a dose friend of the P&dent. and someone 

t5twho is - you know, someone that normally. you know, ou 

[ 6 1 might speak to on a particutar concern that, you know, ): e 

(7 1 have because he is a, you know, a dose frrend of the 

may 

I E I President. also someone who. YOU know, generally has trrettv 

il4 jstatement? 

_ . . 

A He is a dose friend of the President and, I mean 

i iz i I - you know, I dii not - on a day-today basis I did not . 

[ 17 1 have that many dealings with Vernon Jordan. 

(18 1 know, saw him at social events. 

I normally. you 

~:~~Cabinet members in the transition penod, between t e first 

Andduria#atimathatu+were~~ 

121 land second terms, he was very much invotved in the personnel 

tzzlseledion process. And those were the occasions where I saw 

tz3lhim. 

So. in that regard 

I::: high levei rote in terms of -a ‘ IzF 

know he plays a pretty 

ut as high level as a 

1 

CFlCstarr Page 182 to Page 187 
3243 

Page 188 

Leon Panetta, 1128198 

Page 191 

fl! Q DOJOU rxall ~hethec cw not there is Nnning mer 

i 2 1 in the Pantry area. 

[31 A- I believe there is. I believe there is. Because, 

! 4 1 normally, he will - the stewards there will make sou 

rs:actuallr. r ou know - they - I think they have got no 

and 

[ 6 1 a smal s ove and, 

r P* only 

ou know, other ways to kind of fix food, 

[ 7; but Im ’ pretty sure here IS running water there. 

I81 Q I asked ou a series of - 

I9i MR. WISEN$ERG: The - I asked you a series - are 

[ 1 o 1 there any other questions along those lines you all would 

[ 111 like to ask? 

(121 A JUROR: 

[13lpantry. 

Is it possible the one portion is in the 

I141 Q Is it possible, based on your answers, that our 

[ 151 mystery space here could be the Pantry? 

(161 A It - well, you know, Ive ’ noticed. I mean, as I 

[ 17 1 said, I dont ’ know the particular date for this map, but it 

[ 18 1 could well.be that - I mean - that tha! area here that 

[ lslopens up Into Waikway 2 could be the entrance to the Pantry. 

I:fithat area, in that vicini 

I dont ’ know of any other door that leads off of 

other than the Pant door. 

1221 Q Okay. 7 he - so. in other wo r? s, you have got 

1231the - you have talked about the door with the Sea&y bdc. 

[241 A Right. 

1251 - 0 And then youve ’ gal thePatitrydoor. viliichever door 

;: cr know about. that 

: - Vernon getting rnvoived wtth man 

: ‘ Q I ‘

people at that level. 

And were you simf arty surprised to hear that he 

: L had been helpln 

I:: A 3s. 

Ms. Lewinsky to obtain employment? 

i:1 BY MR. BINHAK: 

11:. Q 

1::’ A 

And were you surprised there for the same reason? 

Yes. Yeah, because of his level, and as I 

i 14 described it thats ’ ht. 

1:s: MR. ’ WI&&BERG: Pardon me for just a moment. I 

116: jBBh&mawa~~~ / 

I :6 j conferring with my cc&a 

Pardon us. I apologize for 

ues. 

[19; BY MR. VVlSEaBERG: 

12c: Q You mentioned -when 

(21:two or three historical incidents that ha d 

ou were mentioning early the: 

caused you to 

[zz:speak to the President about the appearance problem, 

if - I believe the only name you could recall wa 

if:- t tha;g.rect? 

s& 

ou 

[2s: 

Page 189 

Q Do you recall that one of these might have involved 

[I j- one of the incidents might have involved Kathleen Willie 

c17; A . No, I havinot. 

MR. WlSENBERG: I am goin to ask you if you would 

I: iistep outside for a few moments and - whi P e I confer with the 

[zo:grand jurors. 

1211 THE WITNESS: Oka 

[221 

[231 

MR. WlSENBERG: Ye$ay the witness be excused? 

FOREPERSON: 

I241 rtness exwsed. Witness recalled.) 

125! r OREPERSON: Mr. Panetta. I would like to remind 

Page 190 

11 :you. you are still under oath. 

I-! ‘ THE WITNESS: Thank ou. 

MR. WISENBERG: Let r he record reflect that we have 

1: ia quorum and that Mr. Panetta has returned. 

[5i BY ‘ MR. WISENBERG: 

16’ Q 

i?ifo( you. 

Mr. Panetta. I have qot a couple more rna~ . auestions . 

My first question is - and actually you dont ’ need 

ii;the map to answer this but my first question is is there 

[ ~o~searity at the Pantry doon In the sense of. nbmber one. 

[ 11 :are there Secret Service agents stationed rght outsii the 

[ 12 1Panb-y door? 

A There - usually in the area between Walkway 2 and 

i :: i Walkway 1 are a combination of Secret Service agents, the 

[ 1 s 1 Presidents ’ detail. and uniform Secret Service indtviduals. 

[i 6 ]the White House police. 

[17! Q You testified that - 

A So that the answer to your uestion is that 

~:~;nonnally that door is watched by-and tha 9 hallway realty 

[zo~is watched by both the a ents as well as the uniform p&z?. 

i::ior uniform 

0 All %ht %ut is there - are there either agents 

olice stationed right at the Pantry doon 

~::~litUe bit be$nd 

Rght at the door, no. They would be either a 

- I mean. they are not standing right in 

[zsjfront of the Pantry door. 

Page 192 

[ 1 Ithat is. and then you have got the door to the Oval Office; 

r . z . I is that correct? 

A The two doors to the Oval Office - or three doors, 

~:~really, I guess. Exterior. 

Q Now-butletme-as-as-intermsofdoors 

iiij - A- That is correct. 

0 Lets ’ start there and lets ’ talk about doors that 

!::!open off of hallways south. Okay. 

1141 A All ri ht. 

1151 Q You 9, avegot that door? 

I161 A Yes. - 

Q Oka Then 

! :i 1 it is the Ii&tie space r o the rig x 

ou have got the Pantry door, whether 

[islone that looks like a - 

t of the fireplace, or the 

[201 

I211 A0 Thats ’ correct. 

t221 A 

- a map of Texas, somewhat? 

That is correct. 

Q Okay. Then your next door that opens southward. or 

I::;in this case would be southeastward, is your door to the Oval 

~zspfice; is that correct? 

4 

Page 193 

111 A Off-yeah, orwalkway - 

121 0 Numbertwo? .~. 

(31 A - No. 2. 

[41 Q All right. So if151 

(61 

“0 gkTye - those are the three doors - 

[?I A - thai I am aware of, that would open into that 

Ielarea. 

t91 Q 

[lolour myste 

So if that little panhandleiih ’ type area in 

room - which I have said looks a little like 

tll]Texas - ifrhat is the door then that room is the Pantry? 

I121 A That is ri ht. 

MR. WlSENBERG: 

i::ithe Pantry 

Okay. Any other questions about 

ou all want me to ask? 

1151 A0 resDonse.1 

Page 188 to Page 193 

- 
3244 

ESA Leon Panetta, 1128198 

Page 194 

! I 1 there. any uniform officer in Receptton Area 1. Oval Offce? 

I?! A No. 

I31 Q 

I41 A 

C$z~y. The rooms that I had gone over before? 

!Sl Q Oka 

[6]would like you to IIS -7en very carefull 

I want to ask you thrs question agaln. I 

[ 7 1 somewhat convoluted questron so ~th~~~wa?$7%g about rt 

[s lyou dont ’ understand I will - I will m-ask rt for you. 

I91 And this question is to go up unttl - up until 

(10 1 now In other words, up until this moment In hme. 

Cl11 Have you heard anything, u 

[ 12jtime. as we speak, from any source J 

until thus moment in 

rch based on your full 

1131 knowledge, erther personal, hearsay, whatever, has caused you 

[ 14 1 to conclude that there may have been sexual actnnty between 

[ 15 1 Monrca Lewinsk and the President? 

A f& there isnt. ’ The only - I mean the only 

I f7”i information that isin ’ m 

I 18 Idiscussion I had with t? 

mind any way relevant was the 

velyn Liebennann. But that clearly 

[ 19 1 did not include any reference to 

tzojactivity. It was the a arance $?rtZ~~V ZZn. 

MR. WISE&?ERG: Let me ask you to step out again, 

I:: iand we might just come and - let me ask you to step out one 

[z 3 1 more time very briefly. 

[241 

rv 

itness excused. Wtiss recalled.) 

L25.1 OREPERSON: You are sbll under oath, Mr. Panetta 

xuuyuj --~- - ___ 

Page 197 

1 ‘ went into the Receptron Area No. 1 woukl dally a (ittk br; 

.: rn the hopes of seerng the Presrdent. 

: Q I guess my question is. other than Monrcs Lewinsk 

: who was transferred out of the White House for dallyin 

:: around - or spending an excessnfe amount of time rn t 

.I where the President was lrkely to be? 

4 e ama 

._ A That was the Only occasion I was aware of. 

.; Q Did you have a sense that the reason she was ask 

: s to leave was precrprtated by 

;:: -oallyrng around or gawking? 

somethrng other than just rnerefy 

A That - I mean, that was not part of the discussion 

jII:l had with Evelyn. I mean I - I kind of - I mean Evelyn 

:;2-and I have a ve 

!;4 :something like, % 

dose relationship. and when she sard 

ou know there IS somebody that is just 

rls:standing arovnd and its ’ - you know - d IS creatin 

tl6:appearanz. w17 kind of understood, you know, w 8 

a bad 

at she meant. 

[?7‘ 

ilJi A I .ust - you know, that - it wasnt ’ - there 

[ 19:wasnt ’ any ques 1. 

t2c:Evel 

Ion n-r my mind that - you know, that if 

n thought that there was a potenbal problem that she 

[zliwoud ty act on it. 

Q 

~:~~underlying 

Was there - was there really a need to explore the 

basis for the problem? 

t24; A Not - I mean. not as far as I was concerned. lf 

12s:shewas concerned that somebody was standing around and she 

Page 195 

(11 THE WITNESS: I understand. 

MR. WlSENBERG: Let the record reflect we have a 

/:iquorum. The witness has returned. 

I41 BY MR. WISENBERG: 

Q I want to try varying to this question again. And 

f z; let me exclude from the auestion newspaper. newspaper 

i 7 j accounts, at least for my question ‘ here. 

181 A Okay. 

Q You have - because when you answered the last 

[ :i jquestion you related it back to the Liebermann incident. 

Have you heard -have you heard anything, other 

1:: i than from newspaper and press accounts from any source, at 

[ 13 1 any time including up to the present, which. based on 

114 jeverhing you know leads you to - leads you to conclude - 

[ 1sljust o conclude, not to a certanty. but to conclude rn your 

I 16 1 mind that there ma 

ty 

have been some sexual activity between 

I 17 I Ms. Lewinskv and he President? 

il8j A - No. 

1191 MR. WISENBERG: 

BY MR. UDOLF: 

Now. are there any questions? 

1201 . 

[:iio 

0 I have a question. lm ’ not goin 

inion or ask for any condusions, but I wou kL?- 

to ask your 

-hR 

lrke to know, 

1231 r. Panetta. earlier you told us that Ms. Liebermann had 

124 jexpressed some concern about Monica Lewinsky% behavior, and 

[ 2 s 1 you described it as generally gawkii or hanging around. 

Page 196 

Do you know what precipitated that partiilar 

i: i report to you was there one particular incident that she was 

[ 3 1 concerned about? 

[ :; 

A No. I dont ’ - I dont ’ know, you know, in 

articular what it was. I assume that Evelyn had seen her 

[ 6 1 P here. or hanging around, and that it was based on that that 

[ 7 1 she had ta$en ;; actpn. 

I81 

ts1 A But r - - 

Q 

specifically what that was, I dont ’ know., 

i if 1 before? Was that an unusual thi 

Had there been equ$ hangmg around or gawking 

i :: lanybod 

A 

g ‘

Well we definitely% to -~~u~;~u&~s;w 

[ 14 1 limit It. 

doing that kind ‘ of thing we wou 

ut thrs was the one instance that I can recall. 

1151 Q He is the President of the United States, and it 

( 16 1 wouldnt ’ kA unui;.al for people to - 

1171 

- I dont ’ know if I would use the term gawk but 

be stare or want to be around the area that he was in:is ‘

f211 A Sure. I mean, I - you know,. there - there 

[ 2 2 1 were - obviously, there were people sornebmes that would be 

[ 23 1 taken throu h the White House that would atways want to catch 

124 ]a glimpse o 3 the President. And. for that matter, even 

t2slemployees withrn the White House would sometimes when they 

LY. 

;ed 

Page 198 

r;:wanted to et rid of them, that is fine with me. 

iii-thin 

a 

that 

So I guess the answer is ou would - if there was 

3, ! 

reapitated her concern r o such a level that 

14 ~she thoug t tha Monrca Lewinsky ought to be banned from the 

f 5 ! West Wing there was no need to - to communicate that 

tslparticular t;c&nn.to you? 

iii BY MR. WtSENBERG: 

t91 Q Given our - 

[lOI MR. WISEdBERG: 

FOREPERSON: 

Oh, Im ’ sorry. 

I have a quick question. Wtiin the 

~~:&mployees that work in the West Wing, along with interns, is 

I 13 j there a written dress code? 

114: THE WITNESS: There are - at the time that interns 

t 15:come it I believe they are briefed as to what they are 

116 jexpected to wear in - 

1173 FOREPERSON: Is it written? 

I:!il have 

THE WITNESS: - their positions. I believe 1 is. 

- I cant ’ tell you that I specificall 

t2ojbut I know that we raised the question x, 

have seen it, 

at we wanted to have 

KKr 

ple briefed properly on what they should wear in the White 

se at all times. And, again, Evelyn would enforce that 

t231code. 

I241 FOREPERSON: Okay. Would Evelyn ever brtr~ to you 

t25 I attention, rn your discussions about inappropriate dress - 

s 

Page 199 

11 nuould she ever bring to our attentiin?hefact that some df 

t2jthe ladres skirts ma be 7 oo short or what type of - 

I31 THE Wl&ESS: Ye;. 

t41 FOREPERSON: - dress cede. 

I51 THE WITNESS: Yes. 

161 FOREPERSON: Dress being too short? 

171 THE WITNESS: 

is jwoukd usual1 

Yeah. If the dress was ~~__ too ._- short _.._._ she -..- 

tell them. 

FdREPERSON: Do you recall in your conversation 

t:z:with MS Liiberrnann if with MS Lewinsky that was ever an 

I 1 I I +e wkh - besides the 

[ 12 lwrth what was expected f? 

awking, was her dress code in tine 

rl3lWhite House? 

om employees in this area of the 

I141 THE WITNESS: I - I dont ’ remember it speci9calfy 

I I 5 I reiatina to. YOU know. to skirt. but aopearance was ane of 

i16jtheco?iceirisshe had. ” ~~ 

t171 FOREPERSON: 

I181 THE WITNESS: 

Do you recall - 

Her appearance. 

I191 FOREPERSON: Do you refallia&&way.her 

jzojappearance was not acceptable? 

THE WITNESS: I dont ’ remember. I dont ’ remember a 

i::;specific discussion about that. Except that 

tz3jjust didnt ’ like the way she looked, and she ,k 

ou know she 

[24]standing around. 

rdnt ’ like her 

[251 FOREPERSON: Thank you. 

6lCStarr Page 194 to Page 199 
3245 

BSA Leon Panetta, II28198 

[ ? I BY MR. UDOLF- 

(11 Cl I have another question. I assume that srnce this 

[ 3 1 story has come out in the past week or so that you have had 

: 4 lseveral discussrons with your fnends and colleagues from the 

: 5 1 Washington area; is that a fair assumptron? About this 

(6 1 matter. 

A Not really that much I mean, I have - I have 

iii been barraged, as you can ima me by a lot of press calls 

island. frankly, I have not respon & to most of them. As to 

: ; o 1 people, you know, that are friends the discussions have been 

I 111 pretty Irmited. 

il2] I havent ’ gone into thrs rssue at all. 

i ::;light peo 

Q Sometimes when things - things like this come to 

[15]this all a P ong.” Or. 

le are like1 to sa Well ‘ yeah,, I knew about 

“rhean?abou-t t; rncrdent a lo? 

r161time ago, or this incident.” Has an one approache 

Y 

ou with 

[ 17 1 anything like that, or told you that t 

tiejcertain 

y were aware o 

r 19 {White 

- certain incidents that they had observed in the 

House? 

A No. 

Q That were related to this matter 

[221 A No. 

i::;that this 

FOREPERSON: By news reports - and Im ’ not saying 

is definite, but I just would like to ask you 

tzslsomething based on a possibility lt was said in the news 

Page 201 

t1 lthat the First Lady.9 

(2 Iweekend. to call nen 

an manning the phones over the 

s and aamer support for the President 

t3jrn these 1 in this crisis. - . 

Did ou receive a phone call from the First Lad or 

i:ithe President z. 

[ 6 ] President durin 

rmsetf over the weekend, to help support t \: e 

this time of crisis? 

[71 THE %ITNESS: NO I did not. 

rs1 FOREPERSON: Thank you. 

191 BY MR. WISENBERG: 

I :i i Lewinsk 

0 If - I want to go back to my example of Ms. 

r121Chief of % 

Lets say that you had heard - you were still 

taff, after the incident with Evelyn Liebermann she 

I 131says she is going to transfer her - for the reasons you have 

I 14 J testified - 

K 

ou assume it is done. 

I151 re you with me so far? 

I161 A Yes. 

(171 Cl You then find out that on approximately tifteen 

[ 18 I occasions this individual has come at various times and been 

rls~allowed access to the West Wing area, including this 

I 20 1 Reception Area 1. 

1211 Are you with me so far? 

I221 A -Yes. 

i::;found 

Q If you found out - I think 

r 

ou said before you 

- if you found it out you would go o Evelyn 

rzsjLiebennann and say, What the t&r rs going on?” Correct? 

XMAIJW) 

Pardon me pst a morner,:. 

[3i U riven me - grven me urcumstances under w!~ch 

14 lshe was transferred out, do you find it stran 

: 5 I- if in fact the press reports are accura!e - 

e. odd, unusual 

w a! she was 

[ 6 ] admitted on about fifteen occasions to the West Wrng Oval 

17 1 Office general are? 

I31 A 

19 1 the Penta 

It IS unusual for an rndrvdual who is assigned to 

on at her level to have that much access. 

!I01 %J So the answer IS? 

1111 A Yes. 

il21 Q Yes? 

[I31 A Yes. 

I141 BY MR. BINHAK: 

Q Who would have had the authority to invite her in 

I :k? j after she had been at the Pentagon - to the West WIngo 

A Well I mean you know - the problem h&e is that, 

[:i;obviously. individuals can piovide a clearance for pea le 

[lglcpming into the White House, They just - you know. P hey 

rzolgtve their name and say, “Thts IS the reason,” that they 

r211should be admitted. And it is a little difficutt to. 

izz jobviousty. track the hundreds upon hundreds bf peo le who - 

I 2x1 and sometiies thousands of people who come into P he White 

124 iHouse on a particular day, or a articular week. 

I251 - So, it is - it is very d’ R icult to oversee, you 

Page 204 

I161 Q All right. And you have testitied that you did not 

[ 17 1 invite her in after that? 

[lBl A Absolutelv not. 

ii9j Q And ou believe that it is not - 

[201 MR. WtSt!NBERG: Liebermann? 

Q Ms. Liibennann you certainty dont ’ think it was 

I:: i her, based on what she told you corns&? 

1231 A No. You better believe if 

r[::;who work In that area of 

Q So - andp have fdenbfred certain other people 

e building. There is Erskine 

Page 202 a Page 205 

Ill A 

Q 

That is right. 

isito the President and demand an explanation - 

And if she said the President said so you would go 

I41 Aa That is right. 

151 - IS that correct? tf you found out that any 

I 6 1 employee. other than the President - you found out that any 

[ 7 jem lo ee had allowed Ms. Lewinsky in, without the knowledge 

I e jof t. Rb. e resrdent. any employee in these approximate1 I 9 I mcidences in my example. would you be ticked at tha r 

tlojemployee? 

A Yes. I - I wouM be concerned if - if she was 

i :f ibeing admitted on a regular basis. no matter who was 

. [ 13 1 responsible. 

I141 Q Would it be fair to say that emplo ee who would do 

[ 15 I that without the knowledge and approval of the 8 

[i6lyou were Chief of Staff, would be gone? 

resident, if 

I:71 A Well, I think you woukt have to - you would have 

I 18 1 to determine, you know, what was involved here, and what the 

I 19 1 nature of th& reason was that was being presented. But if it 

1201was not a sufficient reason, and ifit was, you know, not 

[?I jclear as to. you know, whether there was a specific 

122 Iresponsibility for this person that they were rel 

I z 3 1 then that would be a very serious matter, you l! 

ing on, 

now, as to 

134 iwhat steps we would take. And it would be based on whatever 

12 5 1 information we got. 

t 1 I Bow&, or Harold Ickes, did eftiier afthose peopletett you 

t2 1 that they had invited Monica Lewinsky in? 

131 A I mean, I dont ’ know - what Period are we talkii 

I 4 I about. because - 

151 Q Aftershe161 A - I ma 

[ 7 1 that period. So I don I 

well have left as Chief of Staff during 

know, you know, the particulars. 

I a I The - but Enkine Bowles would not have been there. It 

tslwoukl be probabl 

1101 MR. BlfiHAK: 

Evelyn that was there or Haroid lckes 

Oka . 

BY MR. WtSENBER& 

I have.00 further questions. 

1111 

iizj 0 Do 

t13jof authority to be a r; 

ou have to be at a faidy - at a certain level 

[ 14 jwith a pass? 

le to get somebody into the West Wing, 

1151 A 

[I 6 J 

P 

Yeah. Normal% it is - I Fan. tt would be a 

residential assistant that - w 0 works II) the West Wang. 

I 17 1 hat would allow 

1181 BY MF?%%?ome 13. 

t191 Q 

IZ;President. 

A 

Did Ms. Currie have t&au&o&y? 

Oh, certainly. She is - obviousty. works for the 

[221 BY MR. WlSENBERG: 

Q 

[::ifonns. three or four trmes have 

The question that I have tried to ask in various 

t2sjsource which, based on your ful Y 

ou heard an 

knowledge. ping as caused from any youto 

Page 200 to Page 205 ~_ OlCStan 

- 
Page 206 

3246 

Leon Panetta, 1128198 

I - I honestly am not aware of - I mean I - of 

i:i;someone coming to me, or even through rumor, sayin 

tz2 1 know, they suspect the President is having a relations ithat, you 

tzslwith someone else. 

IP 

I real1 do not recall receiving that kind of 

I::;information. or, r or that matter, even rumor. 

Page 207 

MR. UDOLF: 

FOREPERSON: 

MR. WtSENBERG: 

THE WITNESS: I will. 

MR. WtSENBERG: 

Page 208 

Ill 

[II 

I31 

141 

151 

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1101 

[Ill 

1121 

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L141 

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(231 

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0lcstaiT Page 206 to Page 208 

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3249 

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

-lOFFICE OF THE INDEPENDEhT COUNSEL 

Date of transcription 05/22/98 

STEVEN PHILIP PAPE, white, male, date of birth 0, 

0, United Srates Secret Service (USSS), Uniformed Division was 

interviewed at the Office of the Independent Counsel (OIC), 1001 

Pennsylvania Avenue, NW, Washington, DC, 20004. Also present for 

the interview were Associate Independent Counsel (AIC) MARY ANNE 

WIRTH and AIC MICHAEL TRAVERS, Department of Justice (DOJ) 

attorneys DAVE ANDERSON and JANIS KESTENBAUM, and JOHN ROWLEY, an 

attorney representing PAPE. PAPE was interviewed under the terms 

of an agreemen: between DOJ and OIC. PAPE was apprised of the 

official identity of the interviewers and the nature of the 

interview and thereafter provided the following information: 

PAPE has been employed by the USSS since January 7, 

1991. PAPE was unassigned at the White House for the first four 

years of his career and thereafter was assigned to the Southwest 

gate. PAPE explained that he would work various assignments 

while unassigned, including the Control Center and the Waves 

Center. 

PAPE advised that there are normally three officers 

assigned to the Southwest gate, which is also known as the B-4 

post. PAPE stated that one officer is assigned to the South 

Grounds gate, which is just to the south and east of the 

Southwest gate. The South grounds gate is also known as the B-3 

post. PAPE stated that two officers are in a blocking vehicle 

located on E street, to the south of the White House grounds. 

PAPE said that an additional two officers rotate among the 

aforementioned posts throughout the day. 

PAPE said the officers assigned to the Southwest gate 

and related posts are divided into two sections, the B section 

and the C section. PAPE said the two sections alternate between 

working the 6:30 a.m. to 3:00 p.m. shift and the 3:00 p.m. to 

11:OO p.m. shift. PAPE said his supervisor is Sergeant SAMMY 

ESCAMAILLA. 

PAPE advised the first time he met MONICA LEWINSKY was 

on West Executive Drive, the avenue that runs between the White 

House and the Old Executive Office Building. LEWINSKY was either 

an intern or a White House passholder at the time and she asked 

PAPE about the President's schedule. PAPE told her to look in 

Investigation on 05/18/98 at Washington, DC File # 29D-OIC-LR-35063 
3250 

OIC-302a (Rev. S-19-93) 

29D-OIC-LR-35063 

Continuation of OIC-302 of STEVEN PHILIP PAPE ,On 05/18/98 . Page 2 

the newspaper. LEWINSKY responded with another question about 

the President going to Room 450 of the OEOB. PAPE then told 

LEWINSKY to ask the press. 

Prior to meeting LEWINSKY on the occasion described 

above, PAPE had heard a rumor that LEWINSKY was hanging around 

the West Wing, trying to see the President. In addition, someone 

in the USSS told PAPE that they had seen LEWINSKY hovering around 

the East steps of the OEOB, waiting for the President to pass by. 

PAPE does not recall another encounter with LEWINSKY 

while she worked at the White House. 

PAPE advised that he heard other rumors about LEWINSKY. 

PAPE heard that LEWINSKY was infatuated with the President and 

that she spent a lot of time trying to see the President. PAPE 

heard that LEWINSKY was caught in the family theater of the White 

House with the President. PAPE heard this was the reason 

LEWINSKY and were transferred. 

PAPE never heard about LEWINSKY's job performance. 

Around the time -was transferred, PAPE heard a rumor that 

_ was transferred. PAPE looked' photograph up on the 

computer, to make sure he could identify her if she tried to gain 

access into the White House complex. PAPE heardtermination was not on good terms. 

Eventually, PAPE was formally notified of-being 

transferred. PAPE advised this notification usually takes the 

form of a memorandum or an e-mail. PAPE advised it is not common 

practice to notify the USSS of every employee who leaves employ 

at the White House. However, USSS is notified of those employees 

who leave on unfavorable terms. 

PAPE is not sure if he received formal notification of 

LEWINSKY's transfer. PAPE advised that he heard rumors that 

something was going on between LEWINSKY and the President. PAPE 

also heard that LEWINSKY was a stalker and that she hung out too 

much near the West Wing. 

After LEWINSKY was transferred, PAPE heard various 

rumors about her. PAPE heard stories about LEWINSKY coming to 

see the President after she was transferred. PAPE then saw 

LEWINSKY on numerous occasions at the Southwest gate. PAPE can 

only recall three specific occasions, but believes there were 

more. PAPE advised LEWINSKY typically would come to the 

Southwest gate, show her identification and go into the White 
3251 

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

29D-OIC-LR-35063 

Continuation of OK-302 of STEVEN PHILIP PAPE .On 05/18/98 , Page 3 

House after PAPE would make sure LEWINSKY had an appointment. 

PAPE advised that LEWINSKY would always advise she was 

there to see the President, until the Summer of 1997, after which 

LEWINSKY advised she was there to see CURRIE. PAPE advised that 

when he checked the Waves system to ensure LEWINSKY had an 

appointment, the system would show that LEWINSKY's appointment 

was made by CURRIE, and that LEWINSKY was there to see either 

CURRIE or the President. 

PAPE advised he would typically call the E-l post, the 

next post a visitor to the West Wing would see, to advise 

LEWINSKY was on her way. In addition, PAPE would sometimes call 

CURRIE to advise LEWINSKY was on her way. PAPE does not recall 

ever being notified by CURRIE that LEWINSKY was on her way to the 

White House. 

PAPE heard from Officer SCOTT LEWIS that LEWINSKY came 

to the Southwest gate during the midnight shift, which is between 

11:30 p.m. and 6:30 a.m.. LEWIS said that this incident 

occurred after LEWINSKY left employ and that LEWINSKY came into 

the White House carrying a rose. 

One of LEWINSKY's visits PAPE recalls specifically 

occurred on July 14, 1997. PAPE recalls it was a Monday and PAPE 

was just coming off of leave. LEWINSKY came to the gate and 

asked if she was cleared in to see CURRIE or the President. When 

PAPE said no, LEWINSKY asked if he was sure and told him to check 

the Northwest gate. PAPE did and informed LEWINSKY she was not 

scheduled for a visit. After several minutes, LEWINSKY was 

cleared in to the White House. 

PAPE recalls occasions when he called CURRIE regarding 

LEWINSKY not being entered into the Waves system. On a couple of 

occasions, CURRIE called PAPE to ask whether LEWINSKY could be 

cleared in quickly or without going through the ordinary process 

of scheduling through the Waves system, or to schedule through 

the Waves system after LEWINSKY was already in the White House. 

PAPE refused to honor those requests since LEWINSKY was not 

considered a "VIP." PAPE inferred from CURRIE's tone, or her 

sigh, that CURRIE did not want to clear LEWINSKY in. 

PAPE recalls another specific occasion LEWINSKY was 

cleared in to the White House occurring approximately thirty or 

thirty-two days after the July 14, 1997 incident. PAPE recalls 

clearing LEWINSKY in on a Saturday, around August 16. PAPE 

advised that CURRIE came to the White House in a jogging suit, 

, 
3252 

OIC-302a (Re\ 5-19-94) 

29D-OIC-LR-35063 

Continuation of OIC-302 of STEVEN PHILIP PAPE .OII 05/18/98 , Page 4 

which was not her typical meticulous dress. Five minutes after 

CURRIE arrived, LEWINSKY showed up at the Southwest gate. 

LEWINSKY did not have a previously scheduled appointment, but she 

was scheduled soon thereafter to see CURRIE. Within minutes of 

LEWINSKY gaining access to the White House, PAPE heard on his 

radio that the President moved from the White House residence to 

the West Wing. PAPE advised that CURRIE left the White House five 

minutes after LEWINSKY did. 

PAPE advised he would see LEWINSKY exit the White House 

on some occasions, on others he would not. 

PAPE recalls one occasion, which could have been a 

weekend, when he was training new Officers at the B-4 post when 

he saw LEWINSKY approaching the gate. PAPE told his trainees to 

watch how he handled the situation, because it was "by the book." 

PAPE may have also told the trainees to be careful around 

LEWINSKY, since she was the President's mistress. 

PAPE advised this incident occurred on a very hot 

summer day. PAPE stated LEWINSKY was wearing a blue dress with 

white polka-dots. PAPE advised that officer MYRICK was assigned 

to the gate with PAPE. LEWINSKY was told to call whomever she 

was to meet. LEWINSKY advised she was having trouble getting in 

touch with anyone. 

LEWINSKY had a package she said was intended for the 

President. PAPE described the package as a gift-wrapped box, a 

size large enough to contain a man's cummerbund. PAPE advised 

LEWINSKY asked to sit in the air-conditioned booth, because it 

was so hot outside. LEWINSKY was not allowed to sit in the 

officer's booth, but she eventually gained access to the complex. 

PAPE advised he x-rayed the package, but did not have 

it inspected by the Technical Support Division, as he normally 

would. PAPE explained because LEWINSKY was the President's 

mistress, he did not want to treat her poorly or make her wait 

any more than was necessary, since it could come back on him. 

PAPE also stated that what was in the box would not hurt the 

President. If LEWINSKY wanted to hurt the President, she would 

do what LORENA BOBBITT did. 

PAPE stated that by the time LEWINSKY got into the 

complex, she had sweat stains on her dress, her make-up was 

smeared and her hair was all frizzy. PAPE advised that LEWINSKY 

was wearing a lot of perfume. Once LEWINSKY left their presence, 

PAPE bet MYRICK that the President would move to the Oval office 
3253 

OIC-ML (Rev. S-19-94) 

29D-OIC-LR-35053 

Continuation of OIC-302 of STEVEN PHILIP PAPE ,On 05/18/98 .Page 5 

within ten minutes. PAPE won the bet when the President moved to 

the Oval Office approximately nine minutes and fifty seconds 

after LEWINSKY arrived. 

PAPE heard that it was harder for LEWINSKY to get 

cleared into the White House after the Summer of 1997. 

PAPE was told that on approximately December 29, 1997, 

LEWINSKY came to the White House with a package. Officers OLIVER 

JANNEY and DOUGLAS DRAGOTTA were on duty at the time. JANNEY 

processed LEWINSKY. PAPE assumed she was there to see the 

President. 

PAPE never saw LEWINSKY away from the White House. 

PAPE recalls one incident when LEWINSKY came to the 

Southwest gate while PAPE was in the back of the booth and 

Officer GREG LADOW was the primary officer in the booth. 

LEWINSKY was cleared in as a "press person," and PAPE thinks she 

was there to see MIKE McCURRY. PAPE advised press personnel do 

not normally come through the Waves system. PAPE thinks LEWINSKY 

had trouble getting an appointment with anyone else. 

At one point, LADOW told PAPE that he thought LEWINSKY 

was a threat and LADOW wanted to put LEWINSKY on a "do not admit" 

list. PAPE explained that the USSS's job is to protect the 

President's physical safety as well as his public image. The do 

not admit list has been used for BILLY DALE of the White House 

Travel office, and for former Federal Bureau of Investigation 

(FBI) Special Agent GARY HARLOW. PAPE advised the rumors about 

LEWINSKY and the President were becoming more widespread at the 

time LADOW made the suggestion. 

LADOW went to Lieutenant DAVE WOLTZ, the watch 

commander, to try to restrict LEWINSKY's visits. WOLTZ said that 

it was none of the USSS's business who the President saw. WOLTZ 

added that no one was going to find out about LEWINSKY anyway. 

At about the same time, PAPE was told by GARY BYRNE 

that BYRNE was going to go to someone about LEWINSKY. PAPE 

advised that PAPE heard a rumor that BYRNE spoke to EVELYN 

LIEBERMAN about LEWINSKY. 

PAPE advised that whenever he cleared LEWINSKY into the 

White House, the President would always move to the Oval Office, 

if he was not already there, shortly after LEWINSKY's entry. 

Because of this pattern, each time LEWINSKY came through the 
3254 

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

29D-OIC-LR-35063 

Continuation of OIC-302 of STEVEN PHILIP PAPE ,On 05/18/98 ,Page 6 

Southwest gate, PAPE would call the Control Center to advise 

LEWINSKY had arrived. PAPE stated that he would tell the Control 

Center that, because LEWINSKY had arrived, the Emergency Response 

Team should prepare for the President to move from the Residence 

to the Oval Office. 

PAPE does not recall seeing LEWINSKY escorted by anyone 

from the White House Counsel's Office. 

PAPE heard a rumor about LEWINSKY coming to the 

Northwest gate when BRYAN P&L was on duty. PAPE heard that 

LEWINSKY was told she would have to wait at the Northwest gate 

because another woman was in the Oval Office with the President. 

PAPE advised that once LEWINSKY gained access to the White House, 

she crossed paths with the other woman. 

PAPE advised he heard, as a part of this rumor, that 

Sergeant WILLIAMS and Captain PURDIE are the other names 

associated with this incident. PAPE also heard that CURRIE was 

upset over what was said and the fact that someone would tell an 

outsider what was occurring on the inside of the White House. 

PAPE said CURRIE was the gatekeeper for the President. 

PAPE advised he asked BRYAN HALL about this incident 

approximately two weeks afL, +pr it was supposed to have occurred 

and HALL denied it ever happened. PAPE felt HALL was being 

truthful. PAPE is not aware of any disciplinary action taken as 

a result of the Northwest gate incident. 

PAPE heard a rumor that LEWINSKY was in the Oval Office 

and was seen by NANCY HERNREICH. PAPE heard that Officer JOHN 

MUSKETT was on duty at the E-6 post at the time. HERNREICH got 

upset and told the Chief of Staff, LEON PANETTA, or the Deputy 

Chief of Staff, HAROLD ICKES. MUSKETT was then called by the 

USSS liaison with the White House staff, First Name Unknown (FNU) 

O'MALLEY. O'MALLEY called XiiSKETT to his office to ask MUSKETT 

about the incident. MUSKETT asked O'MALLEY what else he was 

supposed to do in those circumstances. 
3255 

OK-302a (Rev. 8-19-911 

29D-OIC-LR-35063 

Continuation of OIC-M2 of STEVEN PHILIP PAPE .On 05/18/98 , Page _ 

PAPE recalls reading in Newsweek about LEWINSKY having 

couriers bring packages to the White House. PAPE recalls one 

occasion when CURRIE came to the Southwest gate to sign for a 

package that PAPE assumes was intended for the President. PAPE 

advised CURRIE would normally send an aide to retrieve packages. 

PAPE recalls LEWINSKY visiting on a day of significance 

to the President, either his 50th birthday, his wedding 

anniversary or Mother's Day. PAPE recalled he thought it was 

ironic for LEWINSKY to visit on the day he had in mind. 

PAPE recalls speaking to CURRIE approximately two to 

three times, but does not think CURRIE knows his name. 

PAPE provided a hand drawn sketch of the Southwest gate 

area, a copy of which is attached. The original of the sketch 

was filed in an FD-340 with the Agent's original notes of the 

interview. 
3256 
3257 

In Re: Grand Jury Proceedings Mult iUNITED STATES DISTRIC? COURT 

Grand Jury Room NO. 3 

United St.r_es District Court 

for the District ot Columbia 

3rd ‘ ‘onstitution, N.W. 

Washington, D.C. 

Associate Independent Counsel 

MARY ANNE WIRTH 

Office of IndependenC Co"nllel 

100; Pennsylvania *venue. N.W. 

S"ltz 490 Horth 

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Q Sir, would you tell us your full name, please? 

A My full name is Steven, with a “v,” Philip with one 

“1,” Pape, it’s pronounced The last name is P-a-p-e. 

MR. PAGE: Before we get suuted with your 

questions, Madam Foreperson, do we have a quorum? 

THE FOREPERSON: Yes, we do. 

MR. PAGE: And is it cormct to say that there are 

no unauthorized persons in the grand jury room? 

Q 

A 

Q 

THE FOREPERSON: That is correct. 

MR. PAGE: Thank you. 

BY MR. PAGE: 

Is it Officer Pape? 

Yes, sir. 

Officer, I want to go over with you some of your 

rights and responsibilities in your appearance here before 

the grand jury, before we ask you some questions. Okay? 

Washinqcon, D.C. 20004 5 A Okay. 

Page 2 

CONTEHTS 

HIT!zEss: PAGE 

WAND JURY LXILISITS: 

No. SF-i - Report o* interview of Hr. Pape'* in the 

* . 1 

Pagem Wednesday, August 5,1998 

t 

Page : 

PROCEEDINGS 

whereupon, 

STEVEN PHILIP PAPE 

was called as a witness and, having been fim duly sworn by 

the Foreperson of the Grand Jury, was examined and testified 

as follows: 

EXAMINATION 

BY MR. PAGE: 

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Q So please listen up. And if you do have any 

questions as I explain some of these things to you, please 

feel free to interrupt. All right? 

First of all, my name is Edward Page. I work for 

the Office of Independent Counsel. And to my left is Mary 

Anne Wirth, who I understand you may have met before. 

A Yes, sir. 

Q Both of, but primarily Ms. Wirth, will be asking 

you some questions after we go over these preliminary 

lTdtCTS. 

To your left is the court reporter, and it’s her 

job to take down what is being said, both questions and 

answers, during your appearance here. today. Do you 

understand that? 

A Yes, sir. 

Q The first thing I want to review with you is that 

you understand that, under the rules that govern your 

appearance before the grand jury, that what you say hem 

today is secret, as a matter of law, and that only you can 

disclose to others outside the grand jury what took place 

here today. Do you understand that? 

A Yes, sir. 

Q You’ve heard that, probably, called grand jury 

secrecy; correct? 

A Yes, sir. 

Diversified ReDorting Services_ Inc. (202) 296-2929 

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3258 

In Re: Grand Jurv Proceedings Mull Ii1 

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Q Thae are a few exceptions to that. And that is 

that if a court says that the OfEce of Independent Counsel 

can disclose, or should disclose or requires disclosure of 

~tit you said here today. that it would be disclosed -- 

for example, if there is a case in court, Or for some other 

legal proceeding. Do you undastand that? 

A Yes, sir. 

Q So. in other words. the rule is not absolute, but 

it frequently is. Are you following me? 

A Yes, sir. 

Q Under the law, you have certain rights when you 

make an appearance in front of a Federal grand jury, and I 

want to ask you now if you undastand the ones that I’m going 

to ta.lk to you about. 

First of alI, you have the Fifth Amendment right to 

remain silent. Do you understand that? 

A Yes. sir. 

Q Do you understand hu-tber that anything that you 

say caa and may be used against you by this grand jury or in 

a subsequent legal proceeding? 

A Yes, sir. 

Q Do you understand that the only thing that you can 

refuse to answer about arc matters that are privileged? For 

exampt tbe marital privilqz, or the attorney-client 

privilege, or a privilege - 

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A Correct. There’s four. They went over them. 

Q -- or a privilege, psychologist/psychiatrist 

privilge; do you understand that? 

A Yes, sir. 

Q Do you understand further that since the litigation 

has concluded, that there is no such thing anymore as a 

protective function privilege? 

A Yes, I do. 

Q Do you understand that it is your job to claim any 

of those privileges or any others that you think about that 

might pertain to any of your testimony, that it’s not our job 

to do that? 

A Okay. 

Q To help you do that, you have some lawyers here 

present outside the grand jury room, correct? 

A Yes, sir. 

Q Canyoute~uswhotheyare? 

A My attorney is Bruce Blanchard, from Fairfax 

County. I’m also in the union, so Mr. Leibig would also 

offer advice -- L.&big. 

Q Do you have some attorneys from Secret service 

-- for example, Tom Doherty - that are representing you here 

today, as well? 

A -l&y represent the Government, but they’re here. 

Q I represent to you that you’re not a target of this 

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investigation: YOU are a subject in the broadest sense. of 

the investigation. And that is that you are a person wbo the 

Office of Independent Counsel and tk grand jury believes 

that may have peninent information to the matters that the 

grand jury has under investigation. 

A Okay. 

Q Do you understand that? 

A Yes. sir. 

Q Do you understand that. by taking the oath that the 

foreperson administered to you a few momenLs ago. that you’re 

obligated to tell the truth? 

A Yes. sir. 

Q Do you understand that claiming faulty 

recolkction, when that is not accurate, is and can be 

obstruction of justice? 

A Yes, sir. 

Q Do you have any questions before we start? 

A I have none. 

MR. PAGE: Thank you. 

BY MS. WIRTH: 

Q Officer, you’ve been employed by the Secret Service 

since 1991; is that right? 

A Yes,ma’am. 

Q And you arc in the Uniformed Division of the Secret 

Service? 

Page a 

1 A Yes, ma’am. 

2 Q You were unassigned at the White House for the 

3 first four years of your career; is that correct? 

4 A That is correct. 

5 Q Eventually, you were assigned to the Southwest 

6 Gate, or were you assigned to the Southwest Gate during that 

7 period when you wefe unassigned? 

8 A I would also possibly get that assignment. But, 

9 for the last three years, I have been a permanent assignment 

0 at the Main Gate, Southwest Gate. 

1 Q At the what? 

2 A 

3 Q 

4 A 

5 Q 

6 A 

7 Q 

8 post? 

9 A Yes, ma’am. 

0 Q Have you ever met Monica Lewinsky? 

1 A Yes, ma’am. 

2 Q Can you tell us about the first time that you met 

3 her? 

4 A Again, I think the very first time, I don’t know 

At the Southwest Gate, Main Gate. 

For how long, now? 

It wiIl be three years in about 12 days. 

Okay. And that’s been your permanent assignment? 

Yes, ma’am. 

And the. Southwest Gate is also known as the B-4 

5 her status, if she was an intern or passholder at that time. 

Page 5 - Page 8 

Diversified Reportinn Services, Inc. (202) 296-2929 
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1 I bumped into her on West Exec, and -- 

2 Q By “West Exec,” you mean iVest Executive Drive? 

3 A West Executive Avenue, behveen the white House and 

4 the -- and the old buildings, within the complex, the secured 

5 area. 

6 Q And were you working that day? 

7 A Yes, ma’am. 

8 Q What was your post that day? 

9 A It could have been anywhere. It was just everybody 

0 crosses that road to get to their next posf it sfzms like. 

1 Q And what was your interaction with bezr that day, if 

2 any? 

3 A She inquired about the President’s schedule, and 

4 what his schedule was that day. 

5 Q She asked you? 

6 A correct. 

7 Q And what did you say? 

8 A It was -- I tried to kind of blow her off, because 

9 it was not a question most people asked. I think my first 

0 response was, “Check a newspaper.” 

1 Q Did she ask you any other questions? 

2 A I think she asked me that same question twice, or 

3 something to that effect. 

4 Q Did she ever ask you a question about the President 

5 going to a specific room in the old EOB? 

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A Well,yeah,Ithinlc.becausebehad-as1 

remember the schedule, the President was supposed to be 

coming from tbe West Wing into the old building that day, and 

so I think she phrased it a different way, or “Do you know 

when he’s going to, you know, Room 474 Conference Room.” or 

whatever. 

Q In the Old Executive Oftice Building? 

A In the old building. It would have been a bigger 

conference room. 

Q And what did you say to her? 

A Basically, I just, you know, said, “Check the Press 

Office” or, you know, I just kind of blew it off. 

Q Okay. And, to your memory that day, you don’t know 

whether she was an intern or a passholder at the white House? 

A Correct. 

Q But she was anploycd at tbz W’hite House at the 

lime, in some capacity? 

A Well. interns aren’t employed, tbey aren’t paid. 

But she had a -- she had a pass. She was authorized to he 

there. 

Q Allright. Soshewaseitheraninternora 

passholder? 

A Yes, ma’am. 

Q Whenwasthenexttimeyousawha? 

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1 it was, you know -- hmm. 

2 Q Did you ever see her at the Southwest Gate? 

3 A Well, yeah, plenty of times I saw her at the 

4 Southwest Gate. 

5 Q All right. And how many times do you think you saw 

6 her at the Southwest Gate? 

7 A Minimum -- minimum of two, probably thrwz, and I 

8 would say up to at least 10 times I personally cleared her 

9 in. 

0 Q Into the Southwest Gate? 

1 A At the Southwest Gate. 

2 Q I’m a little confused by what you just said. You 

3 said a minimum of two. Is that becaLl!% you recall two 

4 specific dates? 

5 A Inz<wice. 

6 Q And when you say maybe three, and then you said 

7 something like that you cleared her in 10 times, or 

8 approximately 10 times? 

9 A It could be as high as that. 

D Q It could be as high as 10, that’s what you’re 

1 saying? 

2 A Correct. 

3 Q All right. Tell us about the two occasions you do 

4 remember, and if you remember dates, tell us what they are. 

5 Do you remember any occasions last summer, in 1997? 

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A Yeah. I - I tell you what. Last time I gave the 

testimony, I remembered a little bit better. One was in July 

and one was in August. 

Q And when you “testimony,” you had an interview with 

the Office of the Independent Counsel - 

correct. 

-- in the presence of an FBI agent? 

Colnxt. 

And that took place in May of 1998? May, 19987 

Correct. But nor when I cleared her in. 

I understand that. 

YeS. 

And so when you say your manory was better, you’re 

referring to May, as opposed to now? 

A Correzt. 

Q Okay. I had asked you about titnea last summer, in 

1997. when you saw Monica Lewinsky. Do you runemba any 

specific dates on which you saw her? 

A I want to say now it was Iike - before I referred 

to - I had some notes. I referred to them before. 

Q Did you bring your notes with you? 

A No, my attorney has them. 

Q Does your attorney have ihan outside? - 

A I don’t - I don’t think so. He just -- I just 

switched attorneys. So I jus& I mean - 

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notes? 

A He might also have them. I think they both have a 

copy of it right now. 

Q Okay. Who is “they both”? 

A Mr. Riley, my old attorney, and Mr. Blanchard, my 

new attorney. 

Q Okay. But you don’t -- 

A JUROR: Excuse me. I’m having a hard time 

hearing you. 

THE WITNESS: I’m sorry. Mr. Riley was my old 

attorney, and Mr. Blanchard was my new attorney. 

BY MS. WIRTH: 

Q And Mr. Blanchard is outside? 

A Correct. 

Q Does he have your notes outside, do you know? 

A I don’t know, but I would assume he doesn’t. 

MS. WIRTH: Okay. Do you want to take a second to 

check if he does? 

THE WITNESS: Does he? 

BY MS. WIRTH: 

Q Anyway, what is your best memory of when you saw 

Monica Lewinsky last summer? 

A Again, I think one date was on July 18th or 28th, 

:5 or something like that. 

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1 MS. WIRTH: I’m marking as Grand Jury Exhibit SP-I. 

2 for your initials, this report. dated May 22, 1998. which I 

3 represent to you is a report of your interview in tbe Office 

4 of Independent Counsel. 

5 (Grand Jury Exhibit No. SP-1 

6 was marked for identification.) 

7 BY MS. WIRTH: 

8 Q And I’m turning your attention to the bottom of 

9 Page3. 

0 A Okay. 

1 Q And I’ll ask you just to look, to read for a moment 

2 to yourself, and to see if anything t&e refreshes your 

3 menory about when you saw Monica Lewinsky last summer. 

4 A Okay. I would say yes, this is - this is more 

5 accurate. 

6 Q Does it refresh your memory? 

7 A Yes. it does. 

8 Q Okay. And when did you see Monica Lxsvinsky last 

9 summer? 

0 A I believe one was July 14tb and the other was 

!I August 16th. 

!2 Q Tell us about July 14, 1997. Wbat happened that 

!3 day? Where were you postal? 

!4 A My normal post would be the Southwest Gate. And 

!5 again, I’ve dealt with her so many times. I think one time 

1 it was a blistering summer day she bad come up. Humidity was 

2 about 100 percent. It was hot. We knew who she was. I 

3 Q Wben you say “we,” who do you mean? 

4 A The 0th~ officers wbo wpp assigned to the post 

5 tllat day. 

6 Q Is thee a trailer or some kind of a, you know. 

7 enclosure that you were in at tbe %&west Gate? 

8 A It’s a booth. It’s a police booth. 

9 Q Is it air conditioned? 

/I IO A It works, on and off. 

I1 Q Wbat do you remember? Now. you’re telling us. I 

12 believe tbat one of those dates, either July 14th or August 

13 16th~- 

14 A Correct. 

15 Q - was a blistering hot day, you’re not sure which 

16 one? 

:7 A Cortect. 

.8 Q Tell us what you remunber. 

.9 A It was close to 90 degrees. Humidity was about 

!O 100. She bad come up, walked from the Ellipse. Sbe was 

!1 siting. pmtty much profusely, very impatient said that 

!2 she was here for an appointment for tbz President. 

!3 I asked for her driver’s license or Government ID, 

!4 as I ask everybody for. She gave it to me, checked it in the 

15 WAVE system, the computer system. She was not in. I 

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informed her tbat she needs to call a staff member to clear 

her in. 

And I can’t remember. I may have called Betty 

Currie that day or not. Lots of times. if it’s an 

appointment for the President, I take an extra step and call 

-- say, if it was for tbe Presidens I would call Betty and 

say, you know, ‘This person is not cleued in; could you 

please clear her in?’ 

At which point, I mmember. in my notes I made an 

annotation, “Monica is not cleated in again.” 

Q This bad happened befom? 

A Ye&. It’s kind of - for us, it’s kind of 

irritating, because it puts the pressure on us, because it’s 

an appointment for the President. And when they’re not in 

the system it just - you know, you want to get the 

presidential appointments in quick. 

Q Didshcsayshewas~tosctheRcsidentor 

Betty Cut-lie? 

A She-sbewasalwaystbemtoscetbePresident. 

Q Did she say that? 

A Sbe said it the majority of tbe times sbe was 

there, especially earl.& prior to that six would say that. 

Q when you were previously intrxviewed in May of 

1998, according to this repott, on Page 3. the fmt 

~aramaub, you said that Monica L&n&v would always advise 

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1 that she was there to see the President, until the summer of 1 Monday, July 14, 1997, as you sit here today? 

2 1997, when I.zu<nsky advised that she was there to see Currie. 2 A Correct. 

3 Does that sound right to you? 3 Q Do you remember anything else about that day? 

4 A Correct. 4 A Again, one of the two days, it was very hot. Shs 

5 Q Do you have any memory one way or the other 5 came up. She didn’t get in right away. She wasn’t in the 

6 whether, on the day that you’re talking about last summer, 6 system. She kept fanning herself like this (indicating), you 

7 she said she was there to see the President or Betty Currie? 7 know. 

8 A It would have been -- it would have been a 50150 8 Q Indicating with your hand waving at your face? 

9 chance. 9 A Yeah. “I’m hot. Well, can’t I just wait in your 

0 Q But you considered her to be the President’s 10 booth?” You never let somebody wait in your booth, because 

1 appointment, based on your experiera with her? 11 if they’re an appointment, they’re not allowed into the 

2 A Correct, because of the -- ail the other times that 12 complex until they’re cleared. 

3 shehadcomein. 13 I remember, like I said_ she was sweating. I mezn, 

4 Q So you said you wrote in your notes that Monica 14 lotsofsweatonherdress,downherback,inber--this 

5 Lewinsky was not in tbe system again or was not cleared in 15 area (indicating). 

6 again. 16 Q Indicatingyourchest. Goahead. 

7 A Correct. 17 A Correct. Her hair, when a woman’s hair, in high 

8 Q What did you do? 18 humidity -- it was frizzled. And she waited, I would guess, 

9 A Like I said, I May have called Betty and said, you 19 10, maybe 15 minutes in the heat. 

o know, whatever. Or Betty, lots of times, would call down to 20 And, by the time the appointment finally came up 

I me and say, “Could you please let her in?” 21 and was in the system, and she went up to see the President, 

2 And I don’t know if it happened on this date or 22 or Betty, it looked like she went a WJple rounds with 

3 other dates, but the - I mean, I can remember several 23 Mohammed Aii or something. She just -- she looked terrible. 

4 conversations with Ms. Currie, that “I can break a lot of 24 But again, I mean, I was going by the regulations. 

s rules for you, but that’s the one rule I can’t break. I 2s Q And, as you said, you don’t remember whether that 

Page 18 Pqe 2C 

1 mean, they’ve got to be in the system before I can bring them 1 was July, the July visit or the August visit. in 1997, that 

2 into the complex.” 2 was so hot? 

3 Q Do you remember what day of the week July 14th was, 3 A Correct. It could have bum eitba. 

4 1997? 4 Q Okay. Now, is there a particular reason why you 

5 A If I had to guess, I’d say it was a Monday. I had 5 remember August 16, 1997? Is that because there’s a note of 

6 just -- I had come off of vacation. 6 it in your record - 

7 Q Is that why you remember this incident in 7 A Correct. Thae was -- 

8 particular by date, because you had just come off of 8 Q -- or is there some other reason? 

9 vacation? 9 A As1 remanber the notes, both of them indicated 

0 A It was because of that and, last time when you 10 that she was not cleared in the system again. meaning a 

1 questioned me, I looked at my notes right before I walked in. 11 problem for us. 

2 Q So you took a note of that day? 12 On one of those occasions. you know, she’s - you 

3 A Correct. 13 know, she basically, like indirectly threatens you: “Do you 

4 Q Did you write your notes or just a notebook, or 14 know who I’m going to see?” You know, ‘What is he going to 

5 what? 15 say if, you know. I’m late, and he’s waiting for me?” 

6 A Your police notebook. 16 Q Did she say things like that to you? 

7 Q Do you recall whether you wrote anything else down, 17 A Yes, she would. And obviously, if somebody kind of 

8 other than the fact that Monica Lewinsky was not cleared in 18 makes a veiled threat like that, and the person who they’re 

9 again? 19 going to tell us the President of the United States, you take 

0 A No, that - because that was my only problem with 20 note of it. 

I her, pretty much. 21 Q Do you runember what day of the we& the August 

2 Q So there’s a record in your notes of what date this 22 visit was? 

3 was for certain, because you took those notes that day? 23 A I would guess a Saturday. 

4 A Without a doubt, correct. 24 Q Okay. Do you remember anything with respezzt to the 

5 Q And, to the best of your memory, that date iS 25 August 16.1997 visit, &h respect to E3etty Cnrrie and what 

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1 she was wearing that day, or anything that happened that day 

2 with respect to her? 

3 A Correct. Betty drove in her - 1 believe she drove 

4 in her van that day. It looked like she was rushed. like she 

5 was just coming in. She was in a sweatsuit outfit. And 

6 normally. Betty is super professional. dressed to a tee -- I 

7 mean. the way she should. I mean. Saturdays. you didn’t 

8 expect to see her in sweats. 

9 She came in, just minutes before Monica had walked 

1 0 up. And, after her appointment was completed. where she wont 

1 1 to Beuy Curfie’s office, then what I’m assuming to he the 

1 2 President afterwards, when he came down to the -- from the 

1 3 residence. Betty left shortly, like right after - right 

1 4 after Uey were gone. 

1 5 Q Right after -- 

1 6 A Right after -- right after Monica completed her 

1 7 appointment, Betty was out of thae, like the only reason she 

1 8 was there was for this appointmenf to he there. 

1 9 Q So you drew the conclusion mat the only reason 

2 :0 that Betty Cm-tie was them was for Monica Lewinsky’s 

2 :I appointment, because she arrived shortly before Monica 

2 2 arrived and left shortly after Monica left. Is that what 

2 3 you’re telling us? 

2 4 A I believe so, yes. ma’am. 

2 5 Q Now, you mentioned that you were aware that the 

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1 President moved to the Oval Office at some point, on August 

2 16, 1997? 

3 A Yes, 1 am. 

4 Q When did that occur in relation to when Monica 

5 Lewinsky arrived at the White House? 

6 A One of those two days -- because I’m a senior 

7 officer in a section of 16 people, I usually train the 

8 officers. And I had new officer there, and I was -- 

9 Q This is on August 16th? 

10 A On one of the two dates. It could have been the 

.l 16th. 

2 Q That summer, last summer? 

3 A Correct. The officer’s name was Myrick, as I 

4 relnenlber. 

5 Q M-y-r-i-c-k? 

6 A Officer Myrick, M-y-r-i-c-k. 

7 Q Do you know his first name or her first name? 

8 A Robert. And it’sahirn. 

9 Q Go ahead. 

10 A And I had told him, as I had seen her coming up 

11 from the Ellipse, who she was, and I advised him to always g( 

12 by the book: “Don’t do any special favors, especially don’t 

13 let her in unless she’s cleared in, because someday this is 

14 going to come back on us, so always do it by the book.” 

15 I explained -- I basically said that, “This is 

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probably the President’s misee~s. so treat her. you know. 

decent, but again, don’t break the rules for her.” 

And after she left our post and went up to the 

West Wing off&s, I said: “And now watch. The President 

will come down within two minutes.” And he still was 

incredulous that the President would have a mistress: And I 

said ‘This is the way it normally happens. As soon as she 

comes in, within minutes. be comes down, because he’s usually 

late.” 

Q When you say “be comes down,” you mean fmm the 

residence? 

A Fmm the residence or South Grounds. or wherever 

else be may be. He would come instantly, for this person. 

And the officer said, quote, ‘Well, I don’t believe it.” He 

says, “I’ll give you tea minutes, and I hetcha he still won’t 

move.” because it was - you lcoow, it was an early Saturday 

morning or something. 

And I almost lost the bet. It was nine minutes and 

40 or 50 seconds before - before he came down for that 

appoinumrttt. 

Q Meaning the President? 

A Correct. 

Q Moved from the residence to the Oval Oftice? 

A Correct. 

Q And you were aware of that because of your radio? 

Page 2, 

1 A Correct, ma’am. 

2 Q Do you remember whether, on either of those summer 

3 occasions, Monica Lewinsky - last summer, 1997 -- brought 

1 any gifts to the White House? 

5 A Yes. On one of those occasions, she had a gift. 

5 It was gift-wrapped. It had a bow or something around it. to 

7 -- I remember, I didn’t want to unwrap it, because it was for 

8 the President. 

9 Q How did you know that? 

0 A Well, policy is that -- 

1 Q How did you know it was for the President? 

2 A Because she told me it was for the President. 

3 Q Okay. 

4 A Normally, you’re supposed to have a ‘ED agent come 

5 down and personally inspect it. 

6 Q TSPisaspecial7 A T-SD. 

8 Q TSD. What is that? 

9 A Technical Services Division of the Secret Service. 

0 Q And they would check this package for? 

I A Any gifts going to the President, they take a 

2 special interest in, and they like to check before it goes to 

3 him. 

4 Q But they did not come? You did not request them? 

5 A I didn’t request them. 

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Paz: 2’ 

A My aaitude, as I said before, was: “Well, I know 

basically her status; I know where she goes. There hasn’t 

been a problem in the past.’ 

AndIfshewasgoingtodoanyharmtothe 

President, after I looked at the X-ray -- I did X-ray it, and 

there was nothing metal, connecting wires, or anything -- I 

said she would do the -- you know, it would be something 

along the lines of Lorena Bobbit, if she was going to hurt 

him, and that I couldn’t stop. And that’s what was going 

through my mind. 

Q Was it one gift box or more than one gift box? 

A It was one gift box. It was about the size of a 

man’s cummerband, for like a tuxedo. 

Q Can you show us with your hands about how big that 

would be? 

A About the size of that? Sure. (Indicating.) 

Q This folder? 

A I would say a little bit longer. But, you know, if 

you take this (indicating) and squish it a little bit, a 

longer box. 

Q For the record, you just picked up an 8-l/2-by-11 

folder. So a little longer and a little less wide? 

A Correct. And it had very little weight. I 

believe, personally, it was this tie that you read about in 

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tie paper. I’m not sure. But it was - it was Iight, and it 

had like no magnetic or metal w-ature in it. I mean, you 

could see right through the thing 

Q Are you aware of a visit by Monica Lewinsky to the 

White House in December 1957? Did you ever bear about that 

or were you present for that? 

A Yes, I am. I checked my notes again, and I was not 

there that day. The President bad given us one day off for 

Christmas. But, because of my holidays - Friday, Saturday 

- my day fell off on the 28th. my off day. And so I took 

it. 

Q So you were off from December 28th to -- 

A I was off on the 28th, and two other officers on my 

post -- 

Q Which is the Southwest Gate? 

A -- at the Southwest Gate were. tbzre. 

Q And who were those offis? 

A Officer Oliver Janey, Jan-e-y, and Officer 

Douglas Draggotta, D-r-a-g-g--t-a. 

Q Did they, either one of tkm, tell you anything 

that happened on DecRnba 28.1997? 

A Just reglar post conversation. 

Q Let’s srart with this. Did eitha one of them tell 

you about this, of both of them. do you know? 

A Correct. IthinkDougroldmeaboutit. And - 

A Correct. And he said that when this broke -- this 

broke on January 2 1 st, I think, the Monica thing hit th: 

papers. 

Q 1998? 

A And he said, “Hey, we just cleared her in, on like 

the 18th or something. She was just here last month.” And I 

said, “I don’t remember it.” But they didn’t remember l &e 

date, and I think they might have went back and looked at ti 

dates that they worked and I didn’t. 

Q Did they have any specific record that they looked 

at that reflected the date that she was actually there, or 

did they look at a record that showed when they worked the 

Southwest Gate? 

A Again, I don’t know. I’m usually -- I’m pretty 

meticulous, sometimes. I keep notes. I don’t think either 

of them really do. 

Q Did they tell you whether Monica Lewinsky bro@t a 

package to the White House on December 28, 1997? 

A I believe they did. 

Q Did they tell you anything -- 

A Or Douglas did. 

Q Did Douglas Draggotta tell you anything about that 

package? 

A That’s about it, that I remember. He said package 

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Q Do you recall. in your experience, Monica L.ewin&y 

visiting the White House on a day of particular significance 

to the President, such as, you know, a birthday or holiday or 

something like that, or anniversary? Do you remember 

anything like that? 

A Correct. She had come, it seems like, on days that 

she would come, one of them particularly was kind of 

depressing, because I want to say it was the President and 

the First Lady’s, either their anniversary or -- or something 

to that effect. And I just made a mental thought of that was 

not the way to celebrate a traditional family anniversary, in 

my opinion. 

Q Did you make notes of every visit that she made, 

or -- 

A No. I specifically made notes of two times that I 

dealt with her specifically, because she just started, excuse 

my French, but pissing me off, because she would never - sht 

was -- she was a pain in the ass, coming in always. 

Q Okay. And you took notes because you had problems 

with the fact that she was never cleared in the way that you 

felt she was supposed to be; is that right? 

A Correct. 

Q Okay. 

A If something comes back and they say, “Well, bob 

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1 come she was held up,” I could just go back to my notes and 

2 say, “Well, she bias held up on such-and-such a date because 

3 she wasn’t cleared, and no staff members cleared her in.” 

4 MS. WIRTH: Okay. All right. I’m going to ask you 

5 step out for a minute, officer. Thank you. 

6 THE WITXESS: Yes, ma’am. 

7 (Witness excused. Witness recalled.) 

8 MS. WIRTH: Officer, you don’t need to sit down. 

9 Having no questions from the grand jury, with the forelady’s 

0 permission, you are excused. Correct? 

1 THE FOREPERSON: You are excused. 

2 (The witness was excused.) 

3 (Whereupon, at 355 p.m., the taking of the 

4 testimony in the presence of a full quorum of the Grand Jury 

5 was concluded.) 

6 ***** 

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

- 1 - 

OFFICE OF THE WDEPENDENT COUNSEL 

Date of uanscnpoon 05/22/98 

STEVEN PHILIP PAPE, white, male, date of birth-, 

w, United States Secret Service (USSS), Uniformed Division was 

interviewed at the Office of the Independent Counsel (OIC), 1001 

Pennsylvania Avenue, NW, Washington, DC, 20004. Also present for 

the interview were Associate Independent Counsel (AIC) MARY ANNE 

WIRTH and AIC MICHAEL TRAVERS, Department of Justice (DOJ) 

attorneys DAVE ANDERSON and JANIS KESTENBAUM, and JOHN ROWLEY, an 

attorney representing PAPE. PAPE was interviewed under the terms 

of an agreement between DOJ and OIC. PAPE was apprised of the 

official identity of the interviewers and the nature of the 

interview and thereafter provided the following information: 

PAPE has been employed by the USSS since January 7, 

1991. PAPE was unassigned at the White House for the first four 

years of his career and thereafter was assigned to the Southwest 

gate. PAPE explained that he would work various assignments 

while unassigned, including the Control Center and the Waves 

Center. 

PAPE advised that there are normally three officers 

assigned to the Southwest gate, which is also known as the B-4 

post. PAPE stated that one officer is assigned to the South 

Grounds gate, which is just to the south and east of the 

Southwest gate. The South grounds gate is also known as the B-3 

post. PAPE stated that two officers are in a blocking vehicle 

located on E street, to the south of the White House grounds. 

PAPE said that an additional two officers rotate among the 

aforementioned posts throughout the day. 

PAPE said the officers assigned to the Southwest gate 

and related posts are divided into two sections, the B section 

and the C section. PAPE said the two sections alternate between 

working the 6:30 a.m. to 3:00 p.m. shift and the 3:00 p.m. to 

11:OO p.m. shift. PAPE said his supervisor is Sergeant SAMMY 

ESCAMAILLA. 

PAPE advised the first time he met MONICA LEWINSKY was 

on West Executive Drive, the avenue that runs between the White 

House and the Old Executive Office Building. LEWINSKY was either 

an intern or a White House passholder at the time and she asked 

PAPE about the President's schedule. PAPE told her to look in 

Investtgation on 05/18/98 at Washington, DC File # 29D-OIC-LR-35063 
3266 

OIC-302a (Rev. 8-19-o: 

29D-CIC-LR-35063 

Connnuauon of OK-302 of STEVEN PHILIP PAPE .On 05/18/98 ,Page 2 

the newspaper. LEWINSKY responded with another question about 

the President going to Room 450 of the OEOB. PAPE then told 

LEWIKSKY to ask the press. 

Prior to meeting LEWINSKY on the occasion described 

above, PAPE had heard a rumor that LEWINSKY was hanging around 

the West Wing, trying to see the President. In addition, someone 

in the USSS told PAPE that they had seen LEWINSKY hovering around 

the East steps of the OEOB, waiting for the President to pass by. 

PAPE does not recall another encounter with LEWINSKY 

while she worked at the White House. 

PAPE advised that he heard other rumors about LEWINSKY. 

PAPE heard that LEWINSKY was infatuated with the President and 

that she spent a lot of time trying to see the President. PAPE 

heard that LEWINSKY was caught in the family theater of the White 

House with the President. PAPE heard this was the reason 

LEWINSKY and &_ were transferred. 

PAPE never heard about LEWINSKY's job performance. 

Around the time -was transferred, PAPE heard a rumor that 

-was transferred. PAPE looked -photograph up on the 

computer, to make sure he could identify her if she tried to gain 

access into the White House complex. 

termination was not on good terms. 

PAPE heardEventually, 

transferred. 

PAPE was formally notified of-being 

form of 

PAPE advised this notification usually takes the 

a memorandum or an e-mail. PAPE advised it is not common 

pract ice 

at the 

to notify the USSS of every employee who leaves employ 

White House. However, USSS is notified of those employees 

who leave on unfavorable terms. 

PAPE is not sure if he received formal notification of 

LEWINSKY's transfer. PAPE advised that he heard rumors that 

something was going on between LEWINSKY and the President. PAPE 

also heard that LEWINSKY was a stalker and that she hung out too 

much near the West Wing. 

After LEWINSKY was transferred, PAPE heard various 

rumors about her. 

see the 

PAPE heard stories about LEWINSKY coming to 

President after she was transferred. PAPE then saw 

LEWINSKY on numerous occasions at the Southwest gate. PAPE can 

only recall three specific occasions, but believes there were 

more. PAPE advised LEWINSKY typically would come to the 

Southwest gate, show her identification and go into the White 
3267 

01c-302a (Rev. 8-19-94) 

293-OIC-LR-35063 

Continuanon of OK-302 of STEVEN PHILIP PAPE .~n 05/'18/98 .Pape 3 

House after PAPE would make sure LEWINSKY had an appointment. 

PAPE advised that LEWINSKY would always advise she was 

there to see the President, until the Summer of 1997, after which 

LEWINSKY advised she was there to see CURRIE. PAPE advised that 

when he checked the Waves system to ensure LEWINSKY had an 

appointment, the system would show that LEWINSKY's appointment 

was made by CURRIE, and that LEWINSKY was there to see either 

CURRIE or the President. 

PAPE advised he would typically call the E-l post, the 

next post a visitor to the West Wing would see, to advise 

LEWINSKY was on her way. In addition, PAPE would sometimes call 

CURRIE to advise LEWINSKY was on her way. PAPE does not recall 

ever being notified by CURRIE that LEWINSKY was on her way to the 

White House. 

PAPE heard from Officer SCOTT LEWIS that LEWINSKY came 

to the Southwest gate during the midnight shift, which is between 

Ill30 p.m. and 6:30 a.m.. LEWIS said that this incident 

occurred after LEWINSKY left employ and that LEWINSKY came into 

the White House carrying a rose. 

One of LEWINSKY's visits PAPE recalls specifically 

occurred on July 14, 1997. PAPE recalls it was a Monday and PAPE 

was just coming off of leave. LEWINSKY came to the gate and 

asked if she was cleared in to see CURRIE or the President. When 

PAPE said no, LEWINSKY asked if he was sure and told him to check 

the Northwest gate. PAPE did and informed LEWINSKY she was not 

scheduled for a visit. After several minutes, LEWINSKY was 

cleared in to the White House. 

PAPE recalls occasions when he called CURRIE regarding 

LEWINSKY not being entered into the Waves system. 

occasions, 

On a couple of 

CURRIE called PAPE to ask whether LEWINSKY could be 

cleared in quickly or without going through the ordinary process 

of scheduling through the Waves system, or to schedule through 

the Waves system after LEWINSKY was already in the White House. 

PAPE refused to honor those requests since LEWINSKY was not 

considered a "VIP." PAPE inferred from CURRIE's tone, or her 

sigh, that CURRIE did not want to clear LEWINSKY in. 

PAPE recalls another specific occasion LEWINSKY was 

cleared in to the White House occurring approximately thirty or 

thirty-two days after the July 14, 1997 incident. PAPE recalls 

clearing LEWINSKY in on a Saturday, around August 16. PAPE 

advised that CURRIE came to the White House in a jogging suit, 
3268 

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

29D-OIC-LR-35063 

Continuation of OIC-302 of STEVEN PHILIP PAPE ,On OS/19/98 .Page 4 

which was not her typical meticulous dress. Five minutes after 

CURRIE arrived, LEWINSKY showed up. at the Southwest gate. 

LEWINSKY did not have a previously scheduled appointment, but she 

was scheduled soon thereafter to see CURRIE. Within minutes of 

LEWINSKY gaining access to the White House, PAPE heard on his 

radio that the President moved from the White House residence to 

the West Wing. PAPE advised that CURRIE left the White House five 

minutes after LEWINSKY did. 

PAPE advised he would see LEWINSKY exit the White House 

on some occasions, on others he would not. 

PAPE recalls one occasion, which could have been a 

weekend, when he was training new Officers at the B-4 post when 

he saw LEWINSKY approaching the gate. PAPE told his trainees to 

watch how he handled the situation, because it was 'Iby the book." 

PAPE may have also told the trainees to be careful around 

LEWINSKY, since she was the President's mistress. 

PAPE advised this incident occurred on a very hot 

summer day. PAPE stated LEWINSKY was wearing a blue dress with 

white polka-dots. PAPE advised that officer MYRICK was assigned 

to the gate with PAPE. LEWINSKY was told to call whomever she 

was to meet. LEWINSKY advised she was having trouble getting in 

touch with anyone. 

LEWINSKY had a package she said was intended for the 

President. PAPE described the package as a gift-wrapped box, a 

size large enough to contain a man's cummerbund. PAPE advised 

LEWINSKY asked to sit in the air-conditioned booth, because it 

was so hot outside. LEWINSKY was not allowed to sit in the 

officer's booth, but she eventually gained access to the complex. 

PAPE advised he x-rayed the package, but did not have 

it inspected by the Technical Support Division, as he normally 

would. PAPE explained because LEWINSKY was the President's 

mistress, he did not want to treat her poorly or make her wait 

any more than was necessary, since it could come back on him. 

PAPE also stated that what was in the box would not hurt the 

President. If LEWINSKY wanted to hurt the President, she would 

do what LORENA BOBBITT did. 

PAPE stated that by the time LEWINSKY got into the 

complex, she had sweat stains on her dress, her make-up was 

smeared and her hair was all frizzy. PAPE advised that LEWINSKY 

was wearing a lot of perfume. Once LEWINSKY left their presence, 

PAPE bet MYRICK that the President would move to the Oval office 
3269 

OK-3Ma (Rev. 8-19-94) 

29D-OIC-X-35063 

Contlnuanon of or-302 of STEVEN PHILIP PAPE .On 05/18/98 .Page 5 

within ten minutes. PAPE won the bet when the President moved to 

the Oval Office approximately-nine minutes and fifty seconds 

after LEWINSKY arrived. 

PAPE heard that it was harder for LEWINSKY to get 

cleared into the White House after the Summer of 1997. 

PAPE was told that on approximately December 29, 1997, 

LEWINSKY came to the White House with a package. Officers OLIVER 

JANNEY and DOUGLAS DRAGOTTA were on duty at the time. JANNEY 

processed LEWINSKY. PAPE assumed she was there to see the 

President. 

PAPE never saw LEWINSKY away from the White House. 

PAPE recalls one incident when LEWINSKY came to the 

Southwest gate while PAPE was in the back of the booth and 

Officer GREG LADOW was the primary officer in the booth. 

LEWINSKY was cleared in as a "press person," and PAPE thinks she 

was there to see MIKE McCURRY. PAPE advised press personnel do 

not normally come through the Waves system. PAPE thinks LEWINSKY 

had trouble getting an appointment with anyone else. 

At one point, LADOW told PAPE that he thought LEWINSKY 

was a threat and LADOW wanted to put LEWINSKY on a "do not admit" 

list. PAPE explained that the USSS's job is to protect the 

President's physical safety as well as his public image. The do 

not admit list has been used for BILLY DALE of the White House 

Travel office, and for former Federal Bureau of Investigation 

(FBI) Special Agent GARY HARLOW. PAPE advised the rumors about 

LEWINSKY and the President were becoming more widespread at the 

time LADCW made the suggestion. 

LADOW went to Lieutenant DAVE WOLTZ, the watch 

commander, to try to restrict LEWINSKY's visits. WOLTZ said that 

it was none of the USSS's business who the President saw. WOLTZ 

added that no one was going to find out about LEWINSKY anyway. 

At about the same time, PAPE was told by GARY BYRNE 

that BYRNE was going to go to someone about LEWINSKY. PAPE 

advised that PAPE heard a rumor that BYRNE spoke to EVELYN 

LIEBERMAN about LEWINSKY. 

PAPE advised that whenever he cleared LEWINSKY into the 

White House, the President would always move to the Oval Office, 

if he was not already there, 

Because of this pattern, 

shortly after LEWINSKY's entry. 

each time LEWINSKY came through the 
3270 

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

29D-OIC-LR-35063 

Connnuanon of OK-302 of STEVEN PHILIP PAPE ,~n 05/18/99 .Page 6 

Southwest gate, PAPE would call the Control Center to advise 

LEWINSKY had arrived. PAPE stated that he would tell the Control 

Center that, because LEWINSKY had arrived, the Emergency Response 

Team should prepare for the President to move from the Residence 

to the Oval Office. 

PAPE does not recall seeing LEWINSKY escorted by anyone 

from the White House Counsel's Office. 

PAPE heard a rumor about LEWINSKY coming to the 

Northwest gate when BRYAN HALL was on duty. PAPE heard that 

LEWINSKY was told she would have to wait at the Northwest gate 

because another woman was in the Oval Office with the President. 

PAPE advised that once LEWINSKY gained access to the White House, 

she crossed paths with the other woman. 

PAPE advised he heard, as a part of this rumor, that 

Sergeant WILLIAMS and Captain PURDIE are the other names 

associated with this incident. PAPE also heard that CURRIE was 

upset over what was said and the fact that someone would tell an 

outsider what was occurring on the inside of the White House. 

PAPE said CURRIE was the gatekeeper for the President. 

PAPE advised he asked BRYAN HALL about this incident 

approximately two weeks after it was supposed to have occurred 

and HALL denied it ever happened. PAPE felt HALL was being 

truthful. PAPE is not aware of any disciplinary action taken as 

a result of the Northwest gate incident. 

PAPE heard a rumor that LEWINSKY was in the Oval Office 

and was seen by NANCY HERNREICH. PAPE heard that Officer JOHN 

MUSKETT was on duty at the E-6 post at the time. HERNREICH got 

upset and told the Chief of Staff, LEON PANETTA, or the Deputy 

Chief of Staff, HAROLD ICKES. MUSKETT was then called by the 

USSS liaison with the White House staff, First Name Unknown (FNU) 

O'MALLEY. O'MALLEY called MUSKETT to his office to ask MUSKETT 

about the incident. MUSKETT asked O'MALLEY what else he was 

supposed to do in those circumstances. 
3271 

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

29D-OIC-LR-35063 

Conttnuaaon of OK-302 of STEVEN PHILIP PAPE .On 05/18/98 .Page _IL 

PAPE recalls reading in Newsweek about LEWINSKY having 

couriers bring packages to the White House. PAPE recalls one 

occasion when CURRIE came to the Southwest gate to sign for a 

package that PAPE assumes was intended for the President. PAPE 

advised CURRIE would normally send an aide to retrieve packages. 

PAPE recalls LEWINSKY visiting on a day of significance 

to the President, either his 50th birthday, his wedding 

anniversary or Mother's Day. PAPE recalled he thought it was 

ironic for LEWINSKY to visit on the day he had in mind. 

PAPE recalls speaking.to CURRIE approximately two to 

three times, but does not think CURRIE knows his name. 

PAPE provided a hand drawn sketch of the Southwest gate 

area, a copy of which is attached. The original of the sketch 

was filed in an FD-340 with the Agent's original notes of the 

interview. 
3272 
3273 

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

- 1 - 

OFFICE OF THE INDEPENLIEhT COUNSEL 

Dareof transcription l/30/98 

RONALD 0. PERELMAN, white male, born 1-1, 

home address home 

telephone i-3 employed as Chairman of the Board, 

MacAndrews & Forbes Holding-Inc., 35 East 62nd Street, New York 

City, was interviewed in the.-office of his attorney, CHARLES A, 

STILLMAN of the firm of Stillman & Friedman, 425 Park Avenue, 

21st Floor, New York City, telephone 4-b Also present 

during the interview was attorney JOHNB. HARRIS of the same 

firm. 

After being advised of the personal and official 

identities of the interviewers and the purpose of the interview, 

PERELMAN provided the following information: 

On about January 8,1998, PERELMAN received a telephone 

call from VERNON JORDAN, a friend and member of the company's 

Board of Directors. The conversation was very low key and 

casual. During the conversation JORDAN mentioned that JORDAN had 

sent over an application of a terrific young girl and that she 

had met with JAYMIE DURNAN. JORDAN made no specific requests and 

did not request PERELMAN to intervene but PERELMAN volunteered to 

"look into it". 

PERELMAN did not interpret the telephone call as a 

special request by JORDAN but rather that if PERELMAN could be 

helpful, JORDAN would like him to do so. 

PERELMAN could not now recall if JORDAN even mentioned 

the girl's name. PERELMAN, at the time of the"conversation with 

JORDAN, was not aware of a connection between MONICA LEWINSKY, 

President CLINTON and VERNON JORDAN, if any. PERELMAN assumed 

the girl was applying for a low-level job and didn't attach any 

particular significance to the telephone call. 

PERELMAN contacted DURNAN to ask about the application 

and was told by DURNAN that the girl had already been 

interviewed. PERELMAN told DURNAN to see if they could be 

helpful. 

PERELMAN recontacted JORDAN that same day and told 

JORDAN that DURNAN had been instructed to be helpful if DURNAN 

Investigation on l/26/98 

CI - 

at New York City, NY File X 29D-LR-35063 

Date dictated l/30/98 
3274 

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

29D-LR-35063 

Contmuarion of OK-302 of RONALD 0. PERELMAN ,On l/26/98 . Page 2 

could. JORDAN thanked PERELMAN and the conversation ended. 

connected 

described 

by JORDAN 

PERELMAN has had no contact with JORDAN or anyone else 

with the CLINTON -administration since the above 

telephone calls. 

PERELMAN in not. aware of any other recommendations made 

other than WEBSTER HUBBELL. 
3275 

OIC-301 (Rev X-19-94) 

- 1 - 

OF-FICE OF THE INDEPENDENT COUNSEL 

Date of transcnptwn 4/2/98 

RONALD PERELMAN, Chairman of the Board, MC ANDREWS & 

FORBES HOLDINGS (MFH), 35 East 62 Street, New York, New York, was 

interviewed at the law office of STILLMAN & FRIEDMAN, P-C., 425 

Park Avenue, New York, New York. Present at the time of 

interview was his attorney CHARLES STILLMAN, JOHN HARRIS, also of 

STILLMAN & FRIEDMAN, as well as Assistant Independent Counsels 

THOMAS BIENERT and STEVEN BINHAK. 

The offices of MFH on East 62 Street are located in a 

townhouse whose property is adjacent in the rear to a townhouse 

on East 63 Street which is PERELMAN's residence. The telephone 

number used by PERELMAN in his office is r-1 He has 

several additional lines for his use. When PERELMAN wants to 

contact VERNON JORDAN, he calls JORDAN's office number in 

Washington, D.C. He doubts that he has ever called JORDAN at his 

home or ever called JORDAN from his home. PERELMAN said he never 

places telephone calls himself. That is a job performed by his 

secretary. 

PERELMAN is acquainted with VERNON JORDAN_ JORDAN 

serves on the Board of Directors of THE REVLON GROUP, one of the 

corporate entities controlled by PERELMAN. He speaks to JORDAN 

approximately one time per month. He sees JORDAN four times per 

year at company board meetings in New York City. In addition, 

when JORDAN is in New York he sometimes stops by MFH, at which 

time PERELMAN may have casual conversations with him. 

Prior to January 8, 1998, PERELMAN di_d not have any 

discussion with JORDAN regarding MONICA LEWINSKY and was unaware 

that MFH was-involved with her in-any way. PERELMAN said he went 

on vacation on or about December 18 or 19, 1997 for about two 

weeks. He was back at the office just after January 1, 1998. 

On-January 8, 1998, VERNON JORDAN called PERELMAN for 

the purpose of talking about MONICA LEWINSKY. There did not seem 

to be any other reason for the call. JORDAN told him that he had 

"sent a terrific young girl, very smart, for you guys to take a 

look at". He also described her as "very good". PERELMAN told 

him he would look into it. During this call, JORDAN also 

Investigation on 3/27/98 at New York, New York File # 29D-OIC-LR-35063 

by SA Date dictated 4/2/98 -. 
3276 

OIC-3073 (Rev. X-19-9’, 

29D-OIC-LR-35063 

Conrinumon of OIC-302 of RONALD PERELMAN .On WW9a , Page 2 

mentioned that JAYMIE DURNAN had already met with her. There was 

no mention of anyone else at MFH who had talked with LEWINSKY. 

JORDAN did not ask PERELMAN to take any specific action. JORDAN 

did not indicate what level position LEWINSKY was seeking or for 

which she was qualified. 

After JORDAN's call, PERELMAN asked DURNAN to come to 

his office, at which time he told DURNAN-about his conversation 

with JORDAN. DURNAN said that he had met with her recently, 

determined MFH had no position for her, and had forwarded her 

resume to REVLON. PERELMAN then said to DURNAN, "Let's see what 

we can do." DURNAN told him LEWINSKY wasilooking for,a public 

relations job. 

After speaking with DURNAN, he recalls having 

telephoned JORDAN to tell him he had spoken with DURNAN and they 

would do what they could. JORDAN did not indicate there was a 

time constraint in the effort to secure LEWINSKY employment. 

PERELMAN did not document any contacts he had about 

LEWINSKY and did not make any notes. 

PERELMAN had no further information about LEWINSKY 

until the news media started airing stories about the allegations 

of her relationship with President CLINTON. 

PERELMAN had no recollection of personally receiving 

any other telephone calls from JORDAN in which he referred people 

for employment. He is aware that JORDAN sent #&BSTER HUBBELL to 

them for employment; however, JORDAN did not speak to him about 

the matter at the time. 

On or about January 21, 1998, PERELMAN heard the news 

about the allegations of the connection between CLINTON and 

LEWINSKY. He recalled that RICHARD HALPERIN mentioned it to him 

upon arriving at the office. HALPERIN had made the connection 

between the person mentioned on the news and the woman with whom 

they spoke at JORDAN's recommendation. 

Later, on the same day -iJanuary 21, 1998), PERELMAN 

learned that REVLON had made an offer of employment to LEWINSKY. 

A meeting was held at the offices of MFH on that morning to 
327? 

3!C-_402a ‘ (Rev. 8-19-9-l) 

29D-OIC-LR-35063 

Cantrnuation of OK-302 of RONALD PERELMAN .on 3/27/98 . Page _ 3 

discuss the matter. Attending the meeting were RICHARD HALPERIN, 

HOWARD GITTIS, BARRY SCHWARTZ, RONALD PERELMAN, and CHARLES 

STILLMAN, Attorney for MFH. 

PERELMAN has not spoken or communicated with JORDAN 

since January 8, 1998. He has not had any conversation with 

anyone from the White House or anyone known to be representing 

the President. 
3278 
3279 

Ronald Perelman, 4/23/98 

OIC Deposition 

Page 1 to Page 18 1 

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 
3280 

BSA Ronald Perelman, 4123198 

-- --____ _ ~~ XMAX(llIl 

Page 1 Page 4 

il: [:I 

[_! __ _ _-_ _ _.________-__x : 2 :that we only spesk one at a hme. because 

,3 I* ’ 9.E.: ZRr&I J-z9i ’ IVJJES?:;AyION 

,,.______-_____________i 

[ 3 :otherwse she cant ’ get it all down. 

[ii! 

(5: 

So what I WIII ask IS, even when yo; 

I 5already ’ know the answer to something, wart u-2: I 

16: DEPCS:::~!: Cf RONXCJ 0. PEREW, held ac i6;finlSh my queshon before responding. I wrll do 

[71:7.+ offices 35 uessrs. St;l:man, Fr~edxan & Shak, 

[s;;:i par,: Aver.,;.=. sew York, New York 10022, on 

i 7 I my best nz to v;tover you. 

[B: 

[9jT:;rsday. Rprll 23, 1998. commencing at :15:10) [Yl Cl 

[lo'='clock a.m., before Annette Forbes, a Certified 

The other thing is what we are dotng 

[IljShorthand (Stenotype) Reporter and Notary Public 

[ 10 Ihere IS, I am assuming your attorney expjainti we 

[12;iiithin and for the State of New York. 

I I ; i are basrcally replioatrng a grand jury appearance. 

ilZi 

?_. 1131 

Do yoyue;nderstand that? 

A 

r14: Q What we have done in order to make 

i : 5 : life a little easier for you and your emplo ees, 

rlsirather than requiring you to come down o 

I 17 1 Washington 

ty 

and 

[ ia iqoinq to do it In 

o into the grand ury ‘ we are B.. A?_ eoosrbon format ere In New 

r19jYoK 

[201 Do 

[211 A 

[221 

(231 SO 

[241 A 

[251 Q 

Page 2 

I~~APPEARANCE~: 

(31 OFFICE OF THE INDEPENDENT COUNSEL 

1001 Penns lvania Avenue, N.W. 

Id? Suite 490yNorth 

Washington, D.C. 20004 

[51 

BY: THOMAS H. BIENERT. JR., Associate 

(61 lnde ndent Counsel 

:;1 

STEllli~i~INHAK. Assodate Independent 

[91 

[101 

Illi 

t::; 

I::; 

I161 

I:;; 

$091 

[211 

[221 

:;:; 

[251 

[ll 

Page 3 

fz]RONALD OWEN PERELMAN,oalled 

131 as a witness, havin first dul affirmed to 

I41 Annette Forbes, a 8 otary Pu 6. ‘ IIC of the 

I51 State of New York, was examined and 

testified as follows: 

I~~~ExAMNATI~N 

181 BY MR. BIENERT: 

f:zihere. 

Q Mr. Perelman, thanks again for being 

M 

[ :: i Steve Binha 1: 

name is Tom Bienert and this is 

. You may recall that we met a few 

f131weeks agoAwhetey were here. 

I141 

Q Let me go over a few things first so 

I:ziwe all understand the ground rules. 

First of all as you can see we 

i :i i have a court reported here who is takkrg 

[I 9 1 everything down. The main thing is its ’ important 

[ 2 o 1 that you audibly articulate responses instead of 

[ 2 11 using gestures. 

f221 Do you understand that? 

[231 A Yes. 

Q The second thin is because she has 

ii: 1 to get everything down, lets ’ try 9 o make sure 

OICStarr 

-- 

Page 5 

ill 

I 2 I impaneled .Federal Grand Jury that we are going to 

I 3 I be presentmg your testimony to. 

141 You understand that? 

(51 A Yes. 

[61 Cl Because its ’ a Federal Grand Jury 

17 1 looking into possrble federal crimes, everything 

!B I that you say here is subject to the penalty of 

[9 iperluv. 

I101 Do you understand that? 

Ill! A _ Yes. 

[I21 Q Do you understand that perjury is 

[ 13 I the knowtngjy makrng of a materially false 

[ i 4 I statement. 

i151 Do you understand that? 

- 

Page 6 

I11 

[21 Q 

13 IperiUrv? 

Do you have any questions about 

[41. - - A No. 

Q You also have a couple of important 

!zjrights before the grand jury. 

[71 First,, you have a Fifth Amendment 

re~right not to inonminate yourself. 

191 Do you understand that? 

1101 What that means is you have a right 

f 11 Ito.refuse to answer any question if you in good 

t 12 I fa!th bebeve the answer could subjed you to 

I 13 1 onminal punishment. 

I141 Do YOU understand that? 

I151 A -Yes. 

[I61 Q Do you understand that Fiih 

j171Amendment riqht? 

Cl81 A Yes. 

Cl91 .-“.rirk. Q You afsohavea-BMh-Amendmcnt 

,L”,II~IIL. 

[211 What that means is you are entitled 

I 22 1 to opunsel. but because in a 

[23 1 settmg counsel is not allowe 8 r 

rand ju type 

here rn he room. 

124 1 our counsel could be outside, you are absolutety 

I 2 5 I r ree to oonsuk wrth your oounsel as you think 

Page 1 to Page 6 
3281 

esA Ronald Perelman, 4/23/98 uuuw 

Page 7 Page 10 

..i 

[ 2 1 appropriate during our proceedin 

9 

here 

:31 1-I Do vou understand tha 

I41 A Yes. ‘

? 

:5: Q You are represented by counsel 

[ 6 1 today; is that correct? 

I71 A Yes. 

[81 0 Thats ’ Mr. Stillman? 

in fact, in Mr. Stillmans ’

il2j A Correct. 

Q Do you have any questions about your 

i :: 1 Sixth Amendment right? 

A No. 

Page 8 

ill 

[>I Do you understand that? 

(31 A Yes. 

141 Q Any questions before we get going? 

I51 A No. 

I61 Q 

t7 Iwhat your 

Why dont ’ you go ahead and tell us 

Al 

osition IS. give us in a general way - 

I am chairman of the board of 

t89;MacAndrews B Forbes, which is a holding company, 

[loland I am chief executive officer of that company. 

ill] Q 

A 

What is it that you do? 

1121 I basicall monrtor the operations 

Fl3lof all our holdings, whrc .zare for the most part 

r141controlled pieces of consumer products operating 

f I 5 1 companies. 

El61 Q Do you know Vernon Jordan? 

(171 A Yes. 

I191 0 How do ou know him? 

I191 A He is a dy trector of our company. 

1201 Q Which company? 

I211 A Revlon. 

I.221 Q 

A 

How long has he been a director? 

(231 I think about 12 ears. 

Q How often wou you talk to Mr. 

i&!iJordan as a general matter? 

d 

- 

Page 9 

111 

A 

f:;board meetings, w ich are like four brnes a year. 

Irre~lariy. I would sge him at the 

hen occasionally he would pop into 

he had some time while he is New 

Tl 

r:ithe office if 

ts]York. Irregularly. maybe once a month. something 

17 1 like that, he would give me a call. 

Q Have you ever spoken to Mr. Jordan 

i89;about a person named Monica Lewinsky or a person 

I 1 o 1 that you later learned was Monica Lewinsky? 

illj - A Yes. 

Cl21 Q 

A 

How many times? 

I spoke to him one time and I 

I::ibeliive I caked hrm back a second time. 

(151 Q 

A 

On the same day? 

I161 On the same da 

; 

. 

i$iyou would 

0 That would be t e only times that 

have spoken to Mr. Jordan about the 

[ 191 

1201 E 

rson you learned was Monica Lewinsky, would have 

en on that one day? 

1211 A Correct. 

Q 

I:: 1 around Janua 

Would that date have been somewhere 

8th? 

1241 A ?es. 

1251 Q Why dont ’ you describe for us as 

Page 7 to Page 12 

,Z 1 best you can wha! happened in terms of the first 

~~:cmversation that you had with him 

A He cslled me in a ve short, very 

I zj light conversation, indicated that he x ad sent 

[ 61 over to our sho 

P 

the resume of thrs ve 

i 9 i lookat. ’ - 

I 7 lccrnoetent oirl hat he thouoht we shou rd brta %htB ’ e a

Q What I am going to ask you to do, 

[ ;zibecause actually this is what we drd the last 

,I:: tme. I have a auote here. if YOU could rust take 

i ij j us as best 

x 

ou could ‘ through the conversation. 

He said “Hello Mr. Chairman.” He 

I ::~called me Mr. Chairman. He may have said how are 

y takes a look at her, something 

Did he indicate to you that he knew 

122 Ithat she had already seen any others at your 

[23]ofiice, for exampM. Jaymie Duman? 

1241 A Yes. And I said I will take a look 

t25linto it. 

Page 11 

Ill 

[21 

t3linyour: 

He said, she has seen Jaymie Duman 

sho 

[41 8 This is Vernon Jordan telling you? 

I51 A Yes. 

Q He made clear in that conversation 

176ithat he was aware that she had interviewed with at 

I 8 1 least Javmie Durnan? 

i9j 

Cl”. 

_ A, Yes. 

\IV=@ *hat the substance, as best you 

;;yican recall.<f thy&% ersation? 

1121 

[131 Aa EC&F;Zi?+E& else of a 

[ 14 Isubstantive nature that Vernon Jordan indicated 

[ 15 1 that he wanted to speak to you about in that call. 

[ 16 1 except for Monica Lewinsky? 

Page 12 

111 

A I called up Jaymie Duman and had 

I:; him come to my office. And we repeated the phone 

t4 lconversation that I just had with Vernon to 

r5lJaymie. 

He said, “Yes, I already sent her 

i76lover to Revlon.” 

I91 And I said, “Lets ’ see if we can be 

[ 91 helpful in this process.” 

1101 Q 

[IllsaY? 

What, if anything, did Mr. Duman 

A Hesaid I met her I think hesaid 

I::; I met her. I sent her over to Rev/on and I will 

(14 1 just keep on top of it or something to that 

tlsjeffect. 

1161 Q 

r17rcomoanv? 

What is Mr. Dumans ’ position in the 

iiei . * A 

tlg]chairman. 

He is special counsel to the 

[201 Q Does he work under you? 

1211 A Yes. 

Q Is there anybody in the company who 

i::idoesnt ’ work under 

[24]yoU kind of the hea J 

ou in terms of hierarchy? Are 

guy? 

1251 A Im ’ the head guy. 

__ _~~ -__ 

OlCStan 
3282 

BSA Ronald Pehlman, 4123198 

____ XMAX(lq 

Page 13 

1) ‘

;! 

:3i 

Cl Or head person? 

A Head oerson. 

i41 Q 

: 5 I ou do an 

1 7t 

After you s 

P 

oke with Mr. Duman. did 

ewmsky 

hing else In re atron to Monica 

: 6 1 

i71 A I believe that I called Vernon back 

mie and I told him 

: 9 I to see if we can be 

::ijsay to you3 

;I-] ‘ A Thanks. That would have been like a 

; I 3 1 real quick conversation, 15. 20 seconds. 

!I41 Q That would have still been on the 

: 15 1 same day, the 8th? 

i161 A 

! 17 1 recollection. 

I believe so. Thats ’ my 

Cl After this conversation or series of 

I : ii conversations that you had on January 8th when 

120 lwould be the next bme that you heard anything 

1 z 11 that you realized was connected to Monica 

[z z 1 Lewmsky? 

[231 A 

: z 4 1 in the press. 

The day that this was all announced 

(251 Q Does that sound like it would have 

Page 14 

il ’

t z I been arouid Ja+rery ’ 21 st. somewhere around there? 

[31 

[41 Q Tell us about that. 

[51 A I came into the office and somebody, 

(6 I I dqnt ’ recall who, it may have been Howard 

I 7 I GWs, it may have been Richard Halperin, told me 

[E I that the ress had broken the sto 

nR. 

which unfolded 

I 9 1 as the onrca Lewinsky story, an 7 the name didnt ’

told me that this was 

; 12 1 the girt that Vernon ha called about. 

:i31 Q At this time, were you aware as to 

[ 14 lwhether or not your company, Revlon that is. had 

;:slhired Ms. Lewinsk ? 

;161 A At &at moment Im ’ not sure, but 

; 17 1 sometime durin that morning. I did. 

[181 Q &hatifanh 

A Howa;d G’ It? is then began meeting 

rng. happened next? 

i:z;with our lawyers Out of that came the press 

I::; reease ’ ““t ha&z ‘ ~!n%$$prtsed of what 

t231was happening, were you invohf n any of the 

~24 lactual meetings or actions that were taken about 

1251 how to handle it, the fact that it was a public 

Page 15 Page 18 

[II 

I7 1 stolv? 

c-a--- I 

!31 A Not really. 

!41 Q When ou say not really - 

(51 A Well, I i new what was going on. I 

[ 61 knew we were going to issue a press release. but 

17 1 that was it. 

I E! release? 

Q You didnt ’ prepare the press 

1101 A No. 

I-11 ’

iI21 

AQ iY.u didnt ’ issue a press release? 

[I31 0 You didnY set up another meeting 

[I. 4 Iwhere the decision was made about whether to do a 

1 i5 1 press releaAx 04,:s contents? 

:I61 

I:lithat? 

Q Who was sort of your lead guy on 

!I91 A Gittis. I knew they were going to 

! 20 1 issue a press release. 

ifri iinformed? 

Q In other words, you were being kept 

l-731 A 

:241 Q 

To that extent, yes. 

Did you take any notes or write 

[z s I anything down about Monica Lewinsky. either when 

OlCStarr 

Page 16 

::: 

-- ’ ou were talking to Mr. Jordan, when you were 

.j ; alkrng to Mr. Durnan or when you were talkmg to 

-.y 

f 4 ; Mr. Grttis? 

:j: A No. 

A- No. 

iili Q Have you had any communication with 

c13,toL 

[ 1: 1 an one, President Clrnton or anyone that you know 

his representative, in relatron to the 

i : 4 I Monica Lewrnskv incident? 

(151 A No. 

I161 Q Have you had any communication with 

I 17 1 Monica Lewinsk or any representative of hers? 

1181 A N!. 

Cl91 MR. BIENERT: I think thats ’

I201 all I have. 

(211 MR. BINHAK: I have nothing. 

I221 (Whereupon,. at lo:20 octock ’

1231 

1241 

a.m., the deposition was conduded.) 

i25j 

Page 17 

CERTIFICATE 

I: ; STATE OF NEW YORK ) 

r&O”NT& NEWYORK) 

151 

I61 

I1 ’

181 

:91 

LlOl 

ill! 

IlZj 

t131 

I141 

I15! 

[161 

I, ANNETTE FORBES, a Certified 

S,~~~a~~b~~te,;~~~~~~~~~~ 

York do hereby c&ii that the 

fore oin DB osition of the witness 

Ror3d 0. ~~R&IAN taken.at ihe 

and place aforesaid, is a true and 

correct transcription of my shorthand 

notes. 

(171 

1181 

[I91 

1201 

I211 

t221 

1231 

[241 

(251 

I further cert’ 

9 

that I am 

neither counsel or nor related to any 

party to said action, nor in any wise 

interested in the result or outcome 

?l 

7?Of. 

q WITNESS WHEREOF, I have 

hereunto set my hand this 28th day of 

April, 1998. 

-FORBES I I 

time 

111 

(21 

I31 

[41 

[51 

161 

171 

181 

I91 

I101 

1111 

[I21 

1131 

I141 

il5j 

/161 

[171 

[la1 

1191 

I201 

I211 

(221 

1231 

1241 

I251 

Page 13 to Page 18 
3283 

John Podesta, Z/5/98 

Grand Jury 

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: 202-514-8802 
3284 

BSA _.__---~-, 

John Podesta, 2KVS8 ~. xmu(v -__ 

Page 2 

[II 

8 

NITED STATE DISTRICT COURT 

F R THE DISTRI 2 T OF COLUMBlA (2]_____ _______ ______x 

[3lln re: 

I41 GRAND JURY PROCEEDINGS 

L I 

I81 

191 

I::1 

1121 

[131 

Kig 

I171 

I:;; 

[201 

(211 

(221 

1231 

(241 

[251 Washington, D.C. 2ooo4 

Page 3 

PROCEEDINGS 

t i i Whereupon 

JOHN D. PODESTA 

i : i was called as a witness and having been first duly sworn 

[ 5lthe Foreperson of the Grand Jury, was examined and t est%d 

(6las follows: 

171 EXAMINATION 

(91 BY MR. BARGER: 

191 Q Good afternoon. 

[lOI A Hi. 

illI. 9 ..Could you please state your name and spell your 

[ 12 l last name ror me recora. 

[131 A John D. for David, Podesta, P-o-d-e-S-1-a. 

Q Mr. Podesta. you are here today pursuant to a grand 

iK;jury subpoena correct? 

[I61 A That ‘ is correct. 

Cl Mr. Podesta let me o through with you a few 

! :i 1 oreliminarv matters and then we wil ?- 

Page 4 

Q You understand that even though your attorney is 

i:;not allowed in the grand jury room you may consult with him 

[ 3 1 at any time 

(4)foreman - 

just provide reasonable notice to the grand jury 

forewoman, or ourselves. 

I51 Do vou understand that? .-a 

161 A -Yes, I do. 

Q In addition, you, as with an witness, have a right 

Ii 1 not to answer any question shoukt a truth XI 

[ 9~incriminating information against 

I answer provide 

Do you understand tha 

A Yes. 

But you are not at this time a subject or a target. 

A Yes. 

Page 5 

111 Q 

121oath? 

Now you also understand you have been placed und 

(31 A Yes. 

Q And by being placed under oath, ou have an 

I : iobl’ ation to truthfully answer to the best of your 

L6laA. 1 

r, 

kef the 

nowledge 

(7]understand tha 

uestions that will be put before you. Do you 

? 

A Yes, Ido. 

Page 6 

I 11 o&sttwted &ice. ‘ intimidated witnesses 

4 

orotherwise 

era1 

~~$?r%tton 

law other than a Class B or C misdemeanor 

in deabg with m, potenbal 

t4 )witnesses &tomeys, or others concerning the civil case 

t5)Jones v. Clinton.” 

161 DO you understand, in general, what I just read to 

And how long were you there? 

Page 7 

Ill A 

Q 

Approximately 18 months. 

[21 

A 

So approximately from - 

;:;of 78. ‘

I started in 76, ‘ and I left in, I think, January 

Q Thank you. And next afler - after the stint at 

Iz;the Lands Division where did you go? 

A I went to another federal a 

ii{Agency, which at the time ran VISTA and %ea 

ency. called The Action 

ceCorps-no 

[ 91 mr runs Peace Corps - and Retired Senior Volunteer 

rlo)Programs. 

And I served there as a Special Assistant to the 

i :: ; Director of the agency. 

Q Approximately - as best you recollect, 

f ::;approximately how long? 

[151 A 

[161 

[I71 A0 

I was there for probably 18 months again. 

Q 

iTSi remember precisely when I left. 

Thats ’ fine. That IS tine, And 

t::ihappened with regard to employment after - %zz?+ha’ 

( 2 0 1 position? 

A 

I:: / Senate Judicia 

I then wo?ted on Capitol Hill for some time, on the 

r231varietyofSu~CommMee. IwasaCounselto-toa 

[24 IMinonty side. 

ommtttees. both in the Majonty and the 

I251 Democrats lost control - I was on the Democratic 

Page 2 to Page 7 
Page 8 

[ 11 side, working originally for Senator John Culver, from Iowa, 

12 land then Senator Patrick Leah from Vermont. 

I: i that would 

Q So at that porn n tune rf they had lost control .r, . 

I 5 j Counsel? 

mean they are on - it would be like a Minority 

161 A I was Minority Counsel from - 

171 Q Oka 

(81 A 

Q 

1951 to 1986 on the Senate Judiciary Committee. 

191 Okay. And then - and then, what after that? 

A Then I moved to be the Chief Counsel of the Senate 

~:~~Committee on Agriculture. 

(121 0 Ap roximately how long were you there? 

[131 A DI B that for, again approxrmately 18 months. 

[14l Q Oka That would bring us to sometime around 1988? 

1151 A Riah!: .--a 

I161 Q @proximately? 

(171 A RI ht. 

[IsI Q Al?right. 

A Ileft-IIefttheSenatein1988 and 

! :i 1 business with my brother, the title of whii wa; Podes 

an a 

% 

[21 v%sociates. 

1221 Q Generally, without - 

[z3]grea1 detail, I mean generally the na r 

ou dont ’ have to go into any 

ure ofthe business 

[24lwas? 

1251 A We did public affairs work, mostly for non-profit 

Page 9 

[I jdients. and some lobbying for high-tech companies. 

[21 Q And after131 A Mostly for high-tech companies. 

141 Q Im ’ sorrv. Is that - is that - and how bna did 

i 5 j you stay wih that business? 

[61 From 1988 until 196I3, when I joined the Clinton 

(71Administration. 

[ 12 1 position that you now - 

[ 13 1 connection to? 

now you no longer have any business 

A I severed m 

i ::iWhite House for two and a K 

relationship in 1993. I worked in the 

alf years, until July 1 1995. At 

[ 16]that the I k3ft the white HOUse and todc a pOSItiOn aS an 

ri-lladjunct professor at Georgetown University Law Center. 

But while I was adjund professor at Georgetown I 

I:i;did some consulting work for the business. So I ret 20 J associated myself with the business for - and did a liile 

t21lbii of consuttin work wtth them. 

F 

logize. Imean-that-youleft,atleast 

tsne with your brother in approximately 

A January 20. 93. ‘

Page 10 

[II Q And until about July of 95, ‘ during that period of 

rzltime you were - 

r31 A I was at the Whiie House. 

[zithere? 

Q And what position were you in, in the White House 

sent to the President 

[251 A I spent -well - 

Page 11 

r11 Q If anybod 

A It - hope 

I :! little bit over time. 

& Ily somebody (chuckling), it changed a 

I drd answer directly to the 

[ 4 I President, but I was an assistant to the President, answering 

t5lako to the Chief of Staff. 

[61 

And then Mr. Panetta came in? 

Page 12 

Ill Q Let me show you, as a reference, a diagram - 

121 

[31 Aa Uh-huh- or at least a schematic of I believe what is - 

(41 A This is the first floor of the White House. 

151 -thefirstfkxd 

[Cl 2 coned. 

Q 

[l i particular diagram. 

Solour oftice would not be represented on this 

191 A That is correct. It would be - 

[lOI AQ v\?len you were Staff Secretary - 

t::iwould be in essence 

- tn essence - when I was Staff Secretary it 

r1~lsayunde~it,itwouldbeafborbelowl und=mom(*?).*enj ’ 6. 

I141 

I151 A" l?k$it area back there 

Q And you left that posit&r in approximately July of 

!:;195, ’ to become an adjunct professor with Georgetown Law, and 

1181 ou main - and you also - what is the word Im ’ looking 

r191 r or - redeveloped your business relationship with your 

t2ojbrotheR - 

A Thatiscenect,Idki. Aslsay Ididalittle 

:Zlbit ’ of part* consulting, whrcb was albwed under my 

~~~~re”““r&w%~%~r%t~ time when you went back to the 

r2sjVVhite House, as-as an employee? 

Pate 13 

Ill 

121 

A Yes. 

.-~ Q Aobroximatelv when was that? 

131 

(41 

[51 

[61 

A Jiriua of9?. ’

Q And w x ‘ at position did you take at that time? 

A Deputy Chief of Staff. 

Q And who is the current Chief of Staff? 

171 A Enkine Bowles. 

Q Perha 

Ii ; it you then,answer to !A 

s a dumb r$restion. but as the Deputy, I take 

r. B&es. 

I101 A I do. 

Q Oka 

i::iDeputy Chief of Sta h 

. Where is your office physically now, as a 

1131 

(141 

"0 iak; in Room 108. 

I:Zinumber. 

A On x: 4s map (indicating). I didnt ’ know it had a 

MR. WISENBERG: 

I:iiinitials in that blcck where - 

Would you mind putting your 

[I91 THE WITNESS: Sure. (Wirness complied.) 

1201 A (Examinina document.) I iust want to make sure Im ’

i21 i readinq the number. - 

. _ 

i22i - Q Yeah. 

I231 A. Im ’ in 108. 

1241 MR. WlSENBERG: And let the record reflect that I 

r25lam marking this map as - 

-_ - -_-.-____ ___~~~~~~ _ ..- --.-- 

OIC-Starr 
3286 

BSA John Podesta, 215198 xluyg 

Page 14 

I11 MR. BARGER: Use the middle initial - 

121 MR. WISENBERG: What is your middle initial3 

[31 THE WITNESS: D. 

141 MR. WISENBERG: JDP-1. And have I so marked it? 

I51 THE WITNESS: You have. 

(61 BY MR. BARGER: 

Q Can 

Iti i Deputy Chief of Sta #, 

ou tell the members of tha grand my, ‘ as a 

A Sure. I - It ma be helpful to note there are 

qenerall.what your dubes entail. 

1 ~~~two of us. There are two Dep tes who function with the 

I I I ,Chief of Staff. .--. 

I121 Cl The other is? 

A S lvia Matthews. And the two of us sort of support 

~::~the Chief of Sta x and we kind ofdivide the 

[ I 5 J responsibitiis of all of the other White House offces. 

[ 16 J&HIeIal ’

I 17 Jwho wou % 

the units of the White House are run by a person 

be an Ass&ant to the Prasidant. 

So the National Economic Council is a domestic 

i :i 1 polii cuuncif. so essential1 

12otAssrstant to the President. x1 

what it has in it is an 

at woutd, yrata that unit. 

Sylvia and I divide rasponsrbi rty across @I 

I:: iantire White House. We have soma areas of 

[ 23 J but the three Of US really share a lot of work. 

~;$evelopment, work on communcahon strategy. 

One of the two of us deputtes generally travefs 

Page 15 

I201 A NO. 

/Was it - 

Q - that you were requested to ame back and do? 

f231 A The latter. 

1241 

I251 2 @%e is asking me why, right now (chuckling.) 

Page 16 

i22i 

(231 

1241 

.--a 

I251 

A Mr. Bowles - _ 

Q Y~~~uc.&y$ack? 

A - 

Q Right. 

OlCStarr 

Page 17 

A Recruited me. I told him I was reluctant to 

I: 1 back. he convinced me that it was a good thing to do, and 9 

o 

ijjwent.back. 

Q Let me - let me shift to its to some more - some 

I:&ecif~c details that sort of directly rela -I3 e to your - 

( 6 1 inVt?St~ation. 

I71 A Sure. 

Q Dunn 

Ii ~arnployed at the Wh’ P e House, either in your earlier position 

the course of your tima you have been 

1oJor in your current position, did you ever coma to know or 

11 JtxXne ’ in contact with the named individual in our mandate, 

i121Monica Lewinsky? 

A I - I never knew her at the White House. I have 

1:: i met her realty briefly one time And that was more recently. 

1151 Q 

A 

Im ’ sorry. I apologize. You mat her? 

1161 For a few seconds radantty. 

t171 Q And a roxima 

A Decan%rof199. ?y 

when was that that you mat he7? 

J19J 

[I91 Q And can ou tall us. whan? was that? 

A ttwasat Ike - wall rt was at the funeral of 

i:y!Betty Currias ’ brother whose na& is Taddy Wrlliams. 

(22 Jat the Metropokin B&&t Church, in Washington. And 

It was 

[23 J&m yho is an old friend of mine. brother died. her sister 

r 2 4 1 also &ad earlier this 

[25Jthat. and we went - fy 

ear - you probably areaware of 

went up to the funeral service for her 

Page 18 

[ 1 J brother. 

[21 

[3Jit is - 

AndtheservicewasconducttvI I-I-lguess 

J4J Q 

A 

Thats ’ all right. 

fiicondolences to her and her husband. 

-itissomewhata~~u~~~~;~ 

[ 7 J a friend of mine, we had worked together at the Action Agency 

and went to the service. 

ii5 j&eat. I went up, I again expressed condolance~ 

Betty was In their car, I think waiting for this 

~:76~motorcade to move on. She was talkin 

[ 18 1 into the car. I went up, again expre ssa% 

to a woman leaning 

t19Jtell her how 

~:$now - ” 

I rt%!d%i ‘ gave her a 

my condolences and 

h 

“Do 

t22Jsaid “This is 

ou kn&eachothan” sad Ho. 

f& 

“p’ 

she said, Vo&r;mJ_ 

onica Lewinsky.” I said “Ifs nice to met 

1231vou.~ She - Ms. Lewinskv walked d& the street. I then 

i;;jwent back to my car and that - thats ’ the only odd&ion 

t25lWhich I mt her 

Page 19 

Q Other than the brief exchange of greeting with Ms. 

I: i Lewinsky, did you have any conversation wrth her? 

[31 A ~No. 

J4J 0 And just for clarification, Ms. Cunie was inside 

[ 51 the car, and Ms. Lewinsky was the one standing outsiie? 

[Cl A 

Q 

Yeah, she was standin outside. 

Prior to meeting - and 9 dont ’ mean - as you have 

ii{described that contact or that meeting with Ms. Lewinsky, 

I 91 had YOU ever seen her prior to that. to - 

I: ioi _ 

i: “0 Not to -’ 

111 

A 

- the best of your recollection? 

f: 121 Not to the best of my recollection. 

1: Q Had you ever spoken with her, as 

I: ::{that occasion. w.hether_in parson or o.n the phone ! 

ou knew, prior to 

Page 14 to Page 19 
3287 

BSA John Podesta, 2iSl98 

__.~ _.. - ~- -.._ 

XMAX(4) 

Page 20 

111 cover all of this, as far as you recall, 

r 

ou do ,not recall 

(2 1 seeing her at any social functions at he Whne House, for 

f 3 I example? 

IO A No. 

Q Signings or radio addresses, or hand shakings, or 

i z I-- you know - leave takin 

r7lsomewhere. that kind oft ii. 

s where the President is going 

A 

Ing? As far as you recal. 

No. No, but I want to be clear. I didnt ’ - I 

~89~wouldnt ’have re 

=il 

nized her. I didnt ’ know wha! she looked 

1 IO] like, I didnt ’ :;yzr, o she was. 

[Illdidnt ’ re 

So - so, I certainly 

i :: i 

?! 

ou 

Okay. As far as you recall ~TG~!I though 

had not previously met her until MS - 

[ 14 l K rothets funeral, do you recall ever having,any 

I 1 s 1 conversatii y&anyone else about Montca Lewinsky? 

[161 Cl Wfih whom - with whom - with whom have you 

I ::1 conversed about Monica Lewinsky? 

A That is an opened ended question at this point in 

i:z!time. (Chuckli .) 

iZll Q %bestvoucani22i 

[231 

A Well, letine - 

Q Should I put a date on iy? 

1241 

I251 

A Yes. 

Q All right. We will put some context on it. 

Page 21 Page 24 

Ill 

I21 

A Okay. 

Q Prior to January 1st of this year, 1998 - 

I31 

Aa Okay. - do you recall - any conversations. of do you 

1: I recall ever having conversations with anyone about Monca 

I 6 1 Lewinsky? 

i7j _ A Yes. 

Q All right. And with whom, as best you recollect. 

I “, ; were those conversations with? 

1 :y i precisely 

A I initially had a conversation which I cant ’ place 

but I would say late in the spring or early in the 

rlzlsummer.initially ‘ with Mr. Bowles. Mr. Bowles said to me 

rl3lthat - 

[I41 Q This is 19977 

A 1997. And again I cant ’ - I cant ’ place the 

[:i{specifictimefra_monitPage 22 

121 

2 gkztyihe was a friend of MS Curries ’ that she had 

I:iworked in the White House that she had b&sn sent bver to 

[slwork in the Pentagon. Thai, she was unhappy that that had 

[6] happened, and thou 

[7lthat job move. And 8l 

ht that she hadnt ’ been treated fairly in 

at could he look into it. 

181 Q And - and he look into it. maanina Mr - couM Mr. 

iiliBowk 4s look into it? 

A Yeah, could Mr. Btis - I mean, when - in that 

I:!icontext, I think. 

(121 0 As ou understood it? 

A As runderstood it. I mean the - this is not - 

i::tthe President will just often off-load things to Mr. Bow&. 

Q Su-re. 

i:: i you know, 

A 

look 

- there was this person there - that he would, 

into the matter. 

Q From your perspective, the President had enough 

~::~confidence in Mr. Bowles’ discretion that “Here is a task I 

[nslwould like you to take care of, however iou feel, however you 

Page 20 to Page 25 

Page 23 

[ 1 ~feel it should be taken care of. Whether you do it or 

(2 Idesignate someone else to do it, or - 

I31 ; That is correqt. 

- look into this issue.” Okay. As - as you 

i:iunderstood it from Mr. Bowles. this is a conversation that 

[ 6 1 Mr. Bowlei had directly with the President? 

(71 I believe so. That is my recollection. 

Q I-Itakeit-andjustto-andlwillcome 

iiiback to this - but I take it because Mr. &vles was relating 

[ I o 1 the conversation to you that he was tell1 

c I I 1 he wanted you to have some responsibil2 ’ 

you this because 

In looking into 

ilzlthis? _ 

I think he was sort of saying, “What shouM we do 

2% was - it was in the context of a 

[ 11 whatever we need to attend to that day. 

Q Do you remember was this a discussion you had with 

i$;Mr. Bow& in the morning or in dw afternoon. or - 

[41 A I dont ’ rem&nber. 

Q The other - the other items that occurred in the 

t 2 ~course of that conversation so that we might be able to put 

(7 1 a time frame or a context OI!I it, can you eneral describe 

f 6 1 those - without going into an K s Fqhatmi&-might 

191 be in matter - be of matters t a are not relevant to the 

rlolgrand jury - if you understand - 

illi- - -A Yes,l- 

[I21 

1131 AQ Yes. I understan& 

- in other words +mnot~to g&into - 

.--, 

[I41 

[I51 

AQ -& national security issues - 

[I61 

A” 

- or things like that. 

IK!cant ’ reallv. 

I understand. I - I -but my answer is that I 

ii9i -Q Okay. 

A I mean, we were just - I dont ’ rentember this as a 

[:i¶te conversation. 

rzlto do todav?” 

it was just lie, “What have we got 

.--~ 

1231 

[241 

t251 

Page 25 

111 BY MR. WISENBERG: 

121 Q 

A Andyso I dont ’ remember what it was in the context 

Do ou have any - 

i:iof. But we do that eve 

7 

day, so there is, you know, a 

[slthousand items like tha . I cant ’ - I cant ’ pull it out of 

[6]any particular Conversation. 

Q Do you have anything in terms of notes, or diary, 

ii;or calendar that might-you mght be able to look at and 

19 1 pinpoint when this conversation occurred or even some action 

[IO] 

r 

ou might have taken a couple of weeks later that woukl- 

[ 111 hat woukl pinpoint when - around when the first 

r 121conversation occurred bevond. I think YOU said. smina or 

iIJjsummer? 

< . . _ 

A I - I really cant. ’ But I - I have looked for 

i::;notes and -you know HI response to your subpoena, and I 

I 161 have ho notes or caledars - 

ri7i BY MR. BARGER: i;si Q That actua 

[I91 A 

Q 

- in regard l!- o that. 

;&all - 

Im ’ sony. That actually reminds me, I dont ’

,221 .--, A Aaain. this was not a seoarate meetina on this 

[ 2 3 1 matter. 

_ , 

[241 MR. WlSENBERG: Right. 

[251 A I was just in his office, we were going over a list 

..- ..__~__ 

OIC-Starr 
3288 

John Podesta, 215198 

Page 26 

11 lof things and this came up. 

Q 

I: 1 as I recollect? 

The subpoena also asked you to produce documents, 

I41 A Yeah. My subpoena? 

I51 Q _@rrect, your subpoena. 

A Yes. 

Page 27 Page Xl 

is. j like that? 

A No. But - but - but the request wasnt ’ uncommon. 

176iin that the President offloads a tot of stuff. He - 

ts 1 everything from people he meets on a rope-line when he is out 

tglcampaignmg to - to - I always dread when he oea to 

[ 101 Renaissance Weekend, because he comes ba 8withasheafof 

tlllpapers. and cards, and special - you know - requests.. 

And so - and people WI I - WIII raise things wrth 

I::; him and he will raise them with Mr. Bowtes, so it didnt ’ - 

[I 4 1 it didnt ’ strike me as out of the ordinary. 

IIS1 MR. WISENBERG: 

[I61 BY MR. BARGER: 

Okay. Im ’ sorry. Im ’ done. 

Q At the time lt did not - it was not an unusual 

i:itreouest. .--~ . I take it? 

I191 A matis00md. 

~~P~asking is 

Q And just to follow up on what Mr. W~senberg was 

-tothebe&ofyourrecotfactton,had-had 

tzz]the P&dent-or has the President or Mr. Bowles ever 

t231aslced you to look into any other former 

I24 ]employee at the White House who had left en% 

yeas - former 

white House and 

[2s]was unhappy about having to Nave? 

Page 28 

In other words is this the only sort of sour 

I:; rapes emplo ee that you have been asked to fook into, as 

&st you raeaX? 

A Ive ’ had certainly similar cases. I cant ’ think of 

!::anvthina that is exactlv the same. 

.-a- 3. ., 

[cl Q Oka . ’ 

A But r have had - he has asked me to look in 

ii;everything from one who was the father of one of Chefseas ’

[ 9 1 classmates at - in hgh schoot, who when Ron Brown was 

flo~killed and Bill Daley became Secreta 

tiical a pointees an 

~~~$~!%b%ft%~ hirn.P ’ . 

of Commerca~~ reduced 

U-us guy lost hra @I, 

S& 1 wasn - I mean it wasnt ’ - I mean this 

.__,~~~ !::lstuff comes ~~ around in all different directions. 

[I51 ~Q Imsony- ’

A He is President sa s “Take care of these people.’ 

i:f;lf somebody - if it comes to hik a J ention . ‘ ha usually will 

tlaljust pass it. along. So - and there - he - I get lots of 

tlslpersonnel~qu~~~fiom the press. 

(201 

A But fy -but if you are askin 

$:{House employee, who, blah, blah, blah, 

me a former White 

b B ah, I cant ’ think of 

t23lanything - 

(241 Q Okay. 

I251 A - that is directly the same. But it didnt ’ - it 

Page 29 

t 1 Iwasnt. ’ as I say out of the ordinary. 

Q And I understand it ma 

I:;the time or even - even thereafter, bu 

not have been unusual at 

ht 

14 1 of the inquiry now it takes on - wouM 

15 1 takes on some new significance, possibty - possible new 

I151 A Right: 

Q Didhe-didhetalkaboutwhyshehadbeensent 

I:76!to the Pentagon? 

1181 A I donY believe I learned that in that 

i 19 j conversation. 

1201 Q Okay. Did you later learn why she had been - 

1211 

t221 t IA 

sent to the Pentagon? 

$iBetty-on this?” 

i-said to Mr. Bowtes. Why ‘ dont ’ I follow up with 

1251 Q Okay. And right now we will just stick with vour 

r 1 I first conversation with Mr. Bowles. 

I21 A Okay. 

I31 Q You also mentioned that - I think in that 

I q lconversation - Mr. Bowles indited that she wasnt ’

rsland didnt ’ feel like she had bean treated faidv: is that 

happy 

iiicorrect? _. 

171 A That is correct. That is mv recollection. isi 

A” 

r:i{eight months 

%!L of a one-minute conversation that occurrec 

Q qght. Did - during that conversation was there 

i::iany -did you have anytm&&a&i~asto~she<she 

[ 13 1 hadnt ’ been treated fai 

A 

I::; knew what was 

T 

? 

No. But had - I got the information that Betty 

oing on and - 

I161 Q 8kay. Ydu teamed late0 

1171 A I did learn later. 

1181 C! The basis for this? 

I191 

(201 

I211 

1221 ,9>)f 

A Rht. 

MR. OIRIEN: Okay. There you are. 

BY MR. BARGER 

AQ ~~,$a basra for her feelings of being unhappy? 

,‘.-I 

Q B~~tthetirne-atthetknediiyouhaveany 

~~:~perception from Mr. Bowtes as to why she was unhappy about 

Page 31 

OlCStarr Page 26 to Page 31 
BSA 

3289 

John Podesta, 2/S/98 

Page 32 

A She said that Ms. Lewinsk 

i:iMs. Lewinsky. she was a friend of hers ’ t ): 

- she had Fthr$nded 

at she was 

f3tworked in the White House. I - I - again. Ive ’ learned a 

[I llot in the last couple of weeks, and it IS hard to keep all 

tslof this separate. 

161 Q Oka Can 

But lythink w 

ou - 

[71 A K at she said to me at the time - I 

relthink she said to me that she had worked in the East Wing, 

rs@uch 

[loltn the f 

iven - I think that is probably tight - she worked 

ast Wrng, that she was a 

[ 111 young woman. good worker, she 4 

cod ktd. you know a good 

ad become friends wrth Betty 

[ 12 ldunng the course of her employment there, she had come to 

[ I 3 l visit her. 

[I41 That, Ms. Lieberman had decided that she was 

[ 151s 

[16]0 ge the-outoftheWhiteHouse,andfoundherajobinthe 

nding too much time in the West wing, and had moved her 

[ 17 1 Pentagon. And that she felt, you know, that she had been - 

r181you know. sent across the nver - if YOU will. and she felt 

t 19 j badly about that. 

And that she felt like she hadnt ’ done anything 

~:~lwrong, ’ and that she had to pay the consequence for it. 

Q Across the nver is a euphemism, that sometimes 

i:$;refers to the Potomac, right? 

[241 A 

Q 

I was talkrng about the Pentagon. 

t251 Now you - you alluded to the fact that you have 

Page 33 

ri~leamed things recently. I take it from - I take it that 

rzl you just testrfied to, as best you are able to - 

t31 That is my best recollectton of that conversation. 

[41 

Aa 

rslknow now? 

- of what you knew then, as opposed to what you 

i6i A Thatiscorrect. 

0 Okay. Do 

f ~~Currie after Mr. Bow& 1: 

ou recall when it was you talked to Ms. 

as 

[91 

1101 

“0 

ed you to lcok into it? 

$cc;~ Soon thereafter. 

[Ill A I dont ’ know if it was the same day. or the next 

I 12 Iday, but soon after. 

[I31 Q Wtihin a few days, is it fair to say? 

1141 A Yeah. absolutelv. iisi Q Do 

t16lCunie? Was it at &e 

&I recall where it was you talked to Ms. 

White House, on the job, for example, 

(11 

t21 

I31 

Page 34 

Q 

A 

Well, even if they are not in your possession - 

I mean, I dont ’ have any documents. 

Q Yes. but are YOU aware - 

I41 

I51 “0 ~?t% such documents - 

161 

I71 

Aa I d~o$tt+ave ‘ any notes but - 

A F(o. Im ’ unaware of whether anybody else has any 

tzidocuments though. I looked through my records in the White 

[lotHouse. I have a few thin s - nothrn related to this 

I 111 conversation - I proved -Jto the Wh’ I? e House Counsel, that 

[ 12 lwere within the scope of this. 

Q As you understood it from Ms. Currie was it Ms. 

I ii ; Liibermans ’ decision to have MS or Miss Lewinsky moved out of 

tlslthewhite House7 

1161 A That is what Ms. Curie told me. 

Q 

t :z i to looking into the matter? After you talked to ‘ Ms. Cur&. 

Okay. What happened next if anything with regard 

1191 A Real1 what - 

1201 9 Or ,vm sorry. Go ahead. 

- Ms. Cume was askin I 

Lewins was kind of bored 

at the Pentagon, and was 

for another job n the administration. / 

House or at some other agency. 

Page 32 to Page 37 

Page 35 

Q 

I:;conversation with Ms. Cunie or is that - is that the 

Is that - do you recall anything else from your 

r31extent of the conversation with her after you were told by 

14 ]Mr. Bow@ or asked by Mr. Bow& to look into it? 

A I think that - that captures the - ca 

i 211 ’ dont ’ remember anything else. I remember what 

turns it. 

V -howl 

[ 7 1 responded but I dont ’ remember an hrng else that you asked. 

I81 $ :~~~'Pa~~~Y"~~~~~,~~~~~nd? 

[ :i; I didnt ’ know anything about her or what was going on but if 

[ III- that if she wanted - if she. Ms. Lewinsk 

rlz~meIwouMbewtllingtotalktoheraboutt f? IS. 

wanted td call 

[I31 Q Anddidshe? 

i::idont ’ - 

A No, not to the best of my knowledge. I - I 

I161 

2 

i X; notes indicati 

~$~~~&%%~and I have no phone 

Q %at happened next? After you advised Ms. Cunie 

tZ;ofthat what tfanyth’ 

tzltbokik into ihe ma h4z? 

else, happened wfth regard to 

[221 A ljust-itkiiofdroppedatthat. 

1231 Q Didyouever- .. 

I241 A Ifeltlikelhaddonewhatlneeded-to& 

I251 Q Okay. Dii you - 

Page 38 

111 A l121 

A" l?ZXr&mplainL I gave her an avenue for 

I:~punuingitifshewantedto,andthatwasit 

ISI- - Q Andtheavenuewastocall ouandseeA lfshewantedtocallmea rk? talktomeabout 

I76iwhether - whether there were other job opportunities I was 

I 8 lwillina _ to talk with her. 

Q 

[ : 0; ’indirectty. back to h&. Bowles that you had look& into it? 

Did ou - did you communicate either directly or 

Cl11 A I dont ’ - I dont ’ know. I dont ’ think so. I 

I 12 lthink I just tho ht I had handfedit. 

I131 Q %kay. 

1141 A 

[ i 5 l remember. 

I may have said something to them, I just dont ‘

[I61 Q . Okay. To the best of your recollection, did you 

[ 17 I ever communrcate anything back, whether directly or 

[ 18 I indirectly, R theLresldent about the matter? 

1191 

1201 Q Okay. Otherthantelling Be 

[211you, did you communicate anything bade to 

thatshecouldcall 

%e 

t22labout - about the matter, directly or indirectly? 

tty Cunie 

if:iand I was done. 

A I-Ikindoffeltliketheballwasinhercourt, 

lf - lve ’ got a zillion things to do every 

t2slday, and it wasnt ’ like - 

Page 37 

Ill Q 

A 

This wasnt ’ high on the list? 

I: i it on the list. 

This wasnt ’ high on the list and I wasnt ’ keeptng 

lf she wanted to follow up she could follow 

[ 4 I up, and I had done a courtesy for Ms. Currie, who was, as I 

[ 5 1 sard, a close friend of mine. 

[61 BY MR. WlSENBERG: 

171 Q She is a close friend of yours? 

[El A Ms. Cunie. Ms. Currie IS. 

[91 Q Oka . Has she ever - 

I101 MR. WISENBERG: 

r111 MR. BARGER: 

Do you mind if I ask a couple - 

No not at all 

1121 BY MR WISENBERG: 

I131 Q Has she ever asked you directly for a favor like 

[ 14 Ithat, without goi throu h the Prestdent? 

[ISI A a have ?a 

[ 1 slpersonnel, sala 

lked about a variety of things, including 

working conditions that kind of thing 

I171 Q 8 there would be sorb occasions wheie she has 

[ 18 I discussed similar type thin 

[ lslfrom having rt cdme from t l? 

with ynu&ecUy_as 

I2olto you? 

e President through E 

A 

I::l]whether those are similar. 

I - you know 

I’ J 

ou could characterize almost as to 

ont ’ think she woukf have I 

t23lthink if she wanted to have come to talk to me about this she 

[ 2 4 I woukl have felt free to come talk to me about this. 

[251 I -but I - but I didnt ’ read anything much into 

olcstarr 
3290 

asA John Podegta, 26198 xNhxl7l 

Page 38 

11 rthat either. I think if she had - if she had raised it with 

I 2 I the President it would easily follow the track that it went .-. 

r33on. 

I41 0 Okay. But since I wasnt ’ - I wasnt ’ there, and I 

[ srdont ’ want to characterize it incprractly, I will ask you, 

; ,” $0; $v~s~~~~u charadenze R .or.- the thongs that she 

YOU drrectlv as srmrlar n nature to that 

i 8 i request? 

. 

A Im ’ kind of a little bit back on the - on the 

r ~~)pdint I was earlier which is that I think generally similar, 

[ 111 and I think Ms. Che wouM have probably felt open to 

I 12 Idiscuss this with ma if she had thought about it. 

I131 

i Bo”ut”rr. but I cant ’ think of anything that is kind 

t: :iof directly on point that she has brought to ma. 

Q Andlknowitisjusta-yousaiditwasavaty 

! : : ; brief conversation - 

I181 

Cl91 

2 $ cddn;ersatiin with Ms. Cumie? 

1201 A Mr.Bowl&? ‘

1211 Q Mr. Bdwtas, I think your words were - 

1221 A A minute or two. 

1231 - no particular texture to it - 

I241 

1251 

; R’ ht. 

-!# Im ’ not mistaken. And I dont ’ mean to imply 

Page 39 

:76;0n, for just a faw minutes. 

191 BY MR. BARGER: 

[ :z&ith 

Q 

Betty, 

I - I take it, from the - the friendship you had 

if Batty wanted to come talk to you directly she 

t11lcouM have? 

[I21 A Uh-huh. 

Q But in the fact that she didnt ’ wasnt ’ necessarily 

IZ~anything hit ‘ yo&Msd unusual at the time? 

[ISI 

Q Did you ever - did there ever come a tima when you 

!:76& when you had any further conversation with Betty along tha 

~18 ~knes, for example, of, “You know I never heard back from 

rl91her. She must not be interested.” 

In other won% was than9 an 

%nantion. you know, the ball was in Xe Jf~l~~-$pbb you to 

A I dont ’ believe I followed up, and until tha fall I 

IZ!never heard about it again. 

Q And 

IZl]We will come to tha fy 

ou mentioned the fall, we will come to that 

next 

Page 40 

f : ithis - sort of this sprinalsummar tima uariod. 

But just to make sure we have covered the bases on 

Asid49 from 

i3jMr. Bowles and Ms. Cunie, ’ do you rec%ltect whether - 

[I ttalking to an one else other than those two people about that 

[ 51 topic tn - in r hat bme . frame? 

161 A No. 

Q Okay. Now you mentioned the fall. Could 

iii us was there a subsequent - was there some subsequen 

r 91 a&vii in the fall of - approximately the fall of 1997 

r 

ou tell 

rlolthat related to MS or Miss Lewinskv? 

iiij A Yes. 

1121 Q And can you explain to the grand jury what that 

- of this conversation, but - 

111 ’ 0 Oka. 

A 

$Xiat the most. 

I - I ihink this only lasted a couple of minutes, 

Q Do you recall where that ccrnversation oaxrned? 

$FlWas that at the White House? 

1221 A Yeah, it would have been at tha White House. 

1231 Q Ddyourecallwhatharitwasintha1241 A I think it wouldsitberbav&ean inn3yotfice 

125lor - Im ’ often in her office As the grand jurors may know, 

Page 42 

l1~herof8caktheplacewherestaffaasamblato oseethe 

12 1 President. So it is immediately adjacent to the %v al OftIce. 

r31SOYthereis-Iseeherfivetlmesadav. 

And so I am often in her oft%, standing next to 

{:iher desk, waiting until the President ia ready to sea me, or 

t6lthe roup of people that I am with. And so R could - it 

17 1 cm 

[9,sta,%,, next to her Ask. 

have been it ha penad just in the context of - of 

[91 So I dont ’ - I dont ’ nally remember. 

Q I apologize if I have asked you this in ona way or 

ii y ianother. Somatirnas I for et. Has MS Curria ever asked you 

(12 1 to help any other former &a~Nouae&playea&ta.in 

i :: 1emp ’ oyme~t ’ ’ af k% kb”~g$$%kory. 

[ 151 immediately mmes to mi 

I dont ’ - nobody 

, but she B ‘ what - has in tha 

[ 161 past, in my circumstances, my dealings with her over the 

~171 an has helped people find employment. So I didnt ’ think 

[191 K rawas- 

(191 Q She has? 

1261 A SheI211 Q No, I1221 A Ms. Cunie has asked me, or has asked, you know. 

[23] made jdb references. et cetera. 

Q Okay. No - and I dont ’ mean to suggest that there 

~E{is anything unusual - 

Page 43 

111 A Right. 

VI Q Im ’ ust ‘ - 

A But I ‘ cant ’ think of any other former employee who 

i%he asked,? - that she pempnally asked ma to help. 

i1sjcouM come up with anybody that I would - I would go ahead 

r19tand let her know, or, you know, et back to her. 

Q Okay. And what appenad after that? Did yo 

~%~back and tell her? 

R 

r221 A No. 

(231 Q Or did you do something? 

f241 A I did something. 

1251 Q Okay. And what was that? 

make 

.I ‘ come 

-__.. 

OlCStarr Page 38 to Page 43 
Page 44 

A Shortly after that conversation - so I would place 

i:\that conversation in early October - the President took a 

(3rtrip to South America. I was runnin 

I 4 I- as the traveling Chief of Staff on & 

the trip - if you will 

And durin 

e tnp. 

ji;Ambassador Richa r! 

the course of that tri I talked to 

son, from the UN. T&r was in the 

t7lcontext - I believe this occurred on Air Force One. 

But on these fqreign trips you spend a bt of time 

[ $&kkpr heels. And I” - in between. You know, they 

rng and they are tnteresting, but there is also a 

1111 bt of time where you are just doing nothing. As you are 

I 12 leither traveling on the air plane, or you are waiting for a 

t13imeeting. - 

I :: idont ’

I think this actually occurred on the airplane. I 

have a vivid reco8ectiin of it. 

[I61 

A” %% the context of tauting to Ambassador 

~~~+tiichardson whoalsoIhaveknownforawhiteandisafriend 

rls~ofmine.I&edthefactthatMs.Curriehadafriendwho 

i2a jwas moving to New York who was a low level, entry level 

tzl I 

R 

ublic affairs person, anddtd he - could he take a took at 

t221 r, or did he have any low level 

t231hii - in the Mission at - in the U R 

ubtii affairs jobs open in 

Q Okay. As best - I take it the best - your best 

11:1recollection ’ is you believe the first conversation with 

Page 45 

[I IAmbassador Richardson was on the trip, or - 

A I - Im ’ retatively certain rt was on the trip. 

i:;And I think it was on the airplane 

[ 4 1 kind of shootin 

And I think we were just 

tsll ratsed itwith Rim. 

the breeze. And lt popped into my mind and 

A I think what ha 

I:iiforgot about it. (Chuckling.) 

r-red next was that I kind of 

I!& use Mr. Richardsons ’

c 19 ~assistant - I dont ’ know her exact title. but - but I have 

izojknownherforsometime,whose- 

[211 Q Da ourecallhername? 

I223 A Yea K , lsabelfe Watkins. 

1231 Q Okay. 

t241 A Caked my assistant - mixing names up here. 

(251 Q And your assistant? 

Page 46 

A My assistants ’ name is Sarah Latham. Ms. Watkins, 

i:;Richardsons ’ assrstant says to call Ms. Latham and said 

r31”John mentioned some’ person that he wanted &II to take h 

I rl] look at on the trip, or mentioned some 

ISI take a look at, do you have a resume?” 

person they want to 

Sarah knew nothin 

i76ishe told me that lsabelle a 

about this so she asked me - 

ad calted and who was this 

non, and what was goin on. 

,:::~dsw~thisdire~~ 

I &id, “Thats ’ a friend of 

I 9 J ttys ’ ust et - have Be get in touch with lsabelle 

Q Okay. fact that Isabelle calted Sarah suggests 

!::ithat the Ambassador mentioned lt to Isabel@ is that fair to 

rl3lsay? 

t141 A Absolutely. 

IZlnot? 

Q Okay. Do you know whether that is the case, or 

r171 

1181 

“0 pka Ro, I dont ’ know that is the case. 

1191 A But I certainly suggests that. 

(201 

1211 2 :i$% 

[221 Q So the direction was, “Check with Betty.” 

1231 A I told her, I said - 

[241 Q To Sarah? 

I251 A - “It is a friend of 8ettys. ’ tell Betty to deal 

Page 44 to Page 49 

.-...---._.__~~ ~ 

Page 47 

[ 1) with Isabel& directly.” 

Q 

i : i or as you understand it. 

What happened next? At least as far as you know, 

A I remember - the on 

i : 1 this whole transadi was I - and I x 

other thing I remember about 

ave the v uest of 

[ 6 1 recollectiins about this - is that I think 1 bum ainto 

[ 7 1 Bit!. Ambassador Richardson, in the White House, and he 

rslsard - andhetsthereabt,es 

[ 91 of time, he is there quite often Ea 

Ily during this period 

cause he speaks at 

I 1 o I National Security Council meetings - and - 50 I saw him, 

I 11 I literally bum 

I 12 I said to me 

into him in the hallway. And I believe he 

r131We have tic to 6at%?nd of Bettys’” Or, “Of yours. 

at, We re orng to talk to that friend.” Or 

(14 1 Or something like that. 

[I51 

1161 A” I%% really recall exactfy. But - I mean, 

[ 17 I it - I think I knew what he meant. And I just hmA;“ha,” 

rle,recolledionthathe-Ihadthatmuchinteracbon 

Q So asbestyourecollect,ifyou-ifyouindude 

~&?~-well ouhada&aloftwoconversatiinswtthAmbassador 

rz1rRicha d sononeontheairplaneas-orAirForceOne-as 

122 I best you recollect on the second brief encounter at the White 

t231House? 

- A In the halfway, yeah. YmutdaY.hava&tadmore 

I::ithan ten seconds. 

Page 48 

Q As far as ou knew it was Sarahs ’ responsibifii to 

I:;-totakecareofgettkg &e resume, or having Betty get 

I 3 1 the resume to the Ambassadors ’ staff7 

A As far as I knew lt was Sarahs ’ responsibifii just 

~~~tellBettytotakecareofthis. 

[61 - 0 Okay. 

171 A 

Q 

tf she wanted to pursue get a resume out. 

(81 I take it ou didnt ’ do anything beyond that to 

[globtain the resurna, and Lnsmit it to the - 

1101 

1111 : No. - Ambassador7 

A No. 

Page 49 

[ 11 with a reporter about thk. 

Q On - do you recall what day it is we are talking 

i:iabout? Whetherittsthe18tht41 A Do you have a calendar? It is Saturday. 

t51 Q Okay. The 17th. 

(61 A I tho ht it was the 17th 

I71 Q The %y of the Presidents ’ deposition? 

181 A 

Q 

The day of the Presidents ’ deposition. 

Since you mentioned the deposition. just to give 

I %ontext for the members of the grand jury, was there - 

I 11 ldirecting 

? 

our - sounds like Im ’ in court - let me - on 

[ 12 1 January 7th. of 1998 was the President - or did the 

t131President give a deposition in the civil case Jones v. 

r14)Clinton? 

I151 A 

Q 

That is - it is my understanding that he did. 

At least, that is what you understand. All right. 

i :7”; Now, you alluded to having a conversation with a reporter. 

[ 1 B 1 Do you remember what - was lt the same day as the 

rlgjdeposition7 

A Yes. 

Q Okay. Morning. afternoon. evening? 

A The morning. 

Q In oeneral. what did the conversation with the 

i 2 4 j reporter concern?- 

I251 A Well - 

OlCStan 
3292 

Page 50 

John Podesta, 2l5198 

Page 53 

0 

A 

$ossume the reporter contacted you? 

{ IF@4\hyed the reporter. 

A Maybe I should just tell the story. 

Q All riaht. 

1211fkwweek was breaking a bkxkbusterstory. 

Andfortbosaofyouwhoarenotrnthanaws 

i :: i business. this is the way these paopla do business. They 

124 1 kind Of Chase each er around and they - e~3peciatty the 

I 25 I news magaztnes. which - whose deadlines are on Saturday. 

Page 51 

[I11 He cama and he - and he deals a lot with the 

[ 12 I press, and deals a lot with these reporten. 

[ 131nw. We were in the White House, workin 

Came in to sea 

t 14 1 Union and the State of the Union rollout. 8 

on the State of the 

o we had a 

rl5]meetingscbadutad-thiswasonthe17th-thatMs. 

rl61Matthews was chairing and that I was participating in to work 

y;UP the - “a”ke #y$~o_n,~ ~~yfti!f;~ay.ht~ 

A Tbii was on Sajurday. . . 1 

1191 

t201 f Qn Saturday. Im sorry. 

tf:;de 

ht. 

% 

So the Pmsrdant has 

ition. And r. Sosnik cama in he sa d 

one off to do his 

Whars 

t23]on?&hat am all these Time magaine peopki doing??!? 

r9~lc%!ten 

L--l----.-. 

v51 I contacted Ms. Mills, who is tha Deputy White 

Page 52 

I 1 I House Counsel. and said, “Do you know what is 

1211s Starr up to somathing? Are wa in some stories 97 

oing on hare? 

Is 

r3]Newsweek breaking something? Do wa naad to react to this?” 

i:ialso mentioned in these lime conversations 

And tha name of the reporter in - at Newsweek was 

His name is Mike 

~61 Isacof, who is someone I know. So Cheryl s&l to ma - Ms. 

t 7 ] Mills said to ma that she - she had also 

I 8 I Mr. McCurry our Press Secretary, and 

otten calls from 

tslgoing on? %hat is the sto ? 

o &a rs saying, What is 

! :i; hyperventilatin 

Thesepware-Meywenalmost 

[12] breaking and 

ywera-they~stknawsomathingwas 

e dtdn t know wha tt was 

I131 Q do are these people, Tin& 

I141 A Tm. 

1151 

A” zzy& said she had checked with Mr Kendall, who 

1:76iis the Presidents ’

I I 8 I matters, and that R 

rivate attorney in these Whitewater 

r. Kendall had not gotten a call from 

[ 19 1 Newsweek for comment. 

[201 We were concerned - tellin 

] 2 11 we do business - we were concamadga little bit that 

you our business, how 

izz]Newsweek might wait until the very end of the day, call us 

[z3]for comment just before they went to bed, and -and we would 

124 Abe sitting there with some maor ’ story that wa didnt ’ know 

r25]the dimensions of and would Il ave to react to it in the last 

I 1 lfew minutes on Saturday night. 

[21 I satd - kind of took it upon myself to say “Why 

I 3]dont ’ I call Mr.,lsacof and find out what ha is doing.” So 

I 4 ]that we have trma, at least during the day on Saturday, if 

I 5]thare was some bg story breaking that we would be able 

[ 6]ttlerefora to react to it. 

That was not an unusual thing. I have known Mr. 

1 ii; Isacof, as I said, for a few years and I have dealt with him 

I 9]on vanous matters. He has even coma in and tau 

I 1 o rwhan ! w+ at Georgetown Law School, tba rote P 

ht my C&S 

o the 

I 11 I inveshgabve matters. 

press in 

And so I called 

I::isaid to him, Were you -* 

him, and ha said to me that - I 

(14lot-t ast 

.oa: 

what was going on was he working 

about Starr and the grand jury, and ha said, “No.’ 

tis]Hesaid athewasworki 

[i6]hehadputsomacaltsinto “Rt r.Bannatt,tioisthe 

on a Paula Jones story, and that 

I 17 I President% counsel in tha Paula Jonas matter, and coukl I 

[ le~help him get a call ratumed from Mr. Banns&t. 

I::; 

WB 

And I said that I didnt ’ think that was likely 

iven tha fact that Mr. Bennett was at the depositionwith ’

I211 President, but if I could I wwld sac what I could do. 

I221 BY MR. WlSENBERG: 

Q 

%!talkirm about? 

Lets ’ - can wa distinguish what Mr. Bennett we 

.~~_ ” 

1251 A Bob Bennett. 

are 

Page 54 

111 Q Oka 

~51Bennatt - 

A Are &a ra mom Mr. Bannetts? Oh, there is Jackie 

iri 

[Sl 

Q Right, William - 

A He works with vou? 

[61 

171 

[El 

191 

(101 

illj 

Q ihat is . ht. _ 

A Our Mr. % nnett, 

BY MR. BARGER: 

as opposad to your Mr. Bennett. 

Q Ay?p-d to Mr. Bennetts ’ brother? 

A Mr. I I Bennett. who is a critic of the President. 

(Chucklinp.) _ . 

[I21 

A" Ta"e",Y&re not related, are they? Your Mr. Bennett 

f::tis not related to this - 

wh. 

have 

.~~I 

1151 MR. WlSENBERG: Oh - 

1161 Q The other two Bannetts are brothers the 

A In the vast confusion of all this. wa also 

I::; Jackie Bennett who works at the White ._ HI ous4i so- 

[I91 FOREPERSON: Excuse 

1201 MR. BARGER: 

I mfd Mr. Barger. 

1211 FOREPERSON: 

Yes, maam~ ’

I hate to int 

F%zzE 

afnJFybutt22 I 

[231 

a.rv p - 

t241 MR. BARGEF 

ht? 

ZN: 

Iknowwa 

-wanaadto r “m. 

X: Yes. maam. ’ I d id” nY want to 

tss]interrupt the witness in - 

Page 55 

Ill 

I21 

13 Ifollow-ups - 

MR. WISENBERG: It is not a follow-u I think it 

I: ican ba answered very quickly. May I ask three or Pour ’ 

rrrnl~eztinnt7 ,” ‘y--.s..-. ._. 

171 FOREPERSON: Certainty. 

181 BY MS. WlSENBERG: 

191 Q Could we - I would like to have your White House 

r101phone number. 

1111 A 

Q 

0, is the main line that I normal usa. 

[12J 

A 

Is that a direct line to you, or to your o f? ce? 

r131 That is to my office. 

I141 Q Okav. Do vou have a direct line? 

il5j A 

1161 

[I71 AQ 

I181 

I191 

[201 i 

1211 A 

Yes.* 1__ 

t22]number. _ 

1231 

1241 

1251 

OlC-Starr Paae 50 to Paae 55 
3293 

John Podesta, 215138 

Page 56 ! 

Q 

Ii i number is? 

I cant ’ operate it, can you tell me what your I 

[31 Aa lt:tSkypage - can I get this for you? / 

141 I 

i5i A Provide it for the record. 

[61 MR. WISENBERG: Okay. That is all I have got. 

171 At any rate, we are stopping basically and you are 

[e 1 not through - 

191 THE WITNESS: Midstream of - 

[lOI MR. WlSENBERG: 

rlllabdut - 

You are not through talking 

1121 THE WITNESS: - my conversation with - 

I131 MR. WISENBERG: 

THE WtTNESS: 

- your conversation wtth - 

I141 - Mr. Isacof. 

[I51 MR. WISENBERG: - Mr. Isacof. Okay. 

[161 MR. BARGER: I would like tha witness to finish his 

[ 17 J answer and then w8 could st 

FOREPERSON: 

if that is all right? 

~:~~woukf lie to recess. 

o&ase undarstand. tha grand jurors 

MR. BARGER I understand. Can we ask the witness 

i:f;at least how much longer is the answer. approximate how 

t22lmuch more would ou need to r? 

(231 THE AESS: =E !%rn%%s. 

I E i because there are those who are concerned - 

FOREPERSON: Okay. e will - only a very few, 

Page 57 

Cl1 MR. BARGER: Yes, maam. ’

[21 FOREPERSON: - about tha darkness - 

MR. BARGER 

t:; I just think it would ba hard to - to p’ 

Absolut$.b~~ j$;;;$&tety. 

[5lanswer. 

(61 I know. I understand. 

171 BY MR. BARGER: isi. it3 -if YOU cOi&i$~st ba brief. because *e rand 

1 :i i~~~~~~~~a~~~~~~~~~~~~~~~~~ and 

51 

t::;on the Paula Jones sto 

He then- ’ he then - well, he said he was working 

rand juries,” and blah, i6 ‘

I said, Well ‘ what about tapes of 

1141 

II 

bh, blah. He said he - he said 

[ 15 I at he wasnt ’ working on anything related to tha - to the 

[ i 6 1 Starr investigation. 

t :i i asked me a couple more questions about Monica Lewrnsky. 

He then asked me if I knew Monica Lewinsky. And he 

The 

(203A %Tmambe 

t19jon one I particula rwasheaskedmeiflever 

her,lsaidlmet roncebrtaflyatafuneral. Ha 

r2llaskedmewho~efunenlitwas,Isa~,”Nobodyyouknow.” 

[221Andwakindofcutofftheconvemabon 

;::;then?. 

MR. BARGER Wa wfll picic up - wa will pick up 

1251 I dont ’ know exactty what, we have to check with 

Page 58 

t 11 the grand jury on schedules. We will let your attorney know 

tnlwhan to return. 

131 And we would ask that tha witness ba excused fDr 

I71 MIX. DMfx 

18 1 your time and vour I 

i4 jthe day, but he still remains under subpoena. Is that 

[ 5 1 satisfadorp Madam Forelady? 

[61 OREPERSON: That is satisfactory. 

All right. Mr. Podesta. thanks 

a-. 

(91 i: You are welcome. 

1101 iR: You may be excused. 

1111 (The witness was excused.1 

for 

.~~I 

(where@% at4:40 

i::ltestimony in the presetice of a 

.m fhe takin of the 

R r$ 

[14]was concluded.) 

II $orum oft e Grand Jury 

I151 

l **.. 

1161 

[171 

[181 

[191 

I201 

1211 

I221 

[231 

[241 

I251 

Page 0 

[II CERTIFICATE OF REPORTER 

I111 

[121 Thelma M. tdens, Court Reporter 

[I31 

I141 

[151 

I161 

(171 

1181 

I191 

I201 

[211 

1221 

I231 

1241 L 

1251 

%ge 56 to Page 0 

- _ _ 

John Podesta, 6/l 6198 

Grand Jury 

Page 1 to Page 96 

CONDENSED TRANSCRIP \ND CONCORDANCE 

PREPAF,i BY: 

oj- SE OF THE INDE t ZNDENT COUNSEL 

1001 Pennsylvai . . Avenue, N.W. 

Suite 4? Vorth 

Washington, .X 20004 

Phone: 20: ,L 14-8688 

FAX: 202 4-8802 
Page 1 

II! UNITED STATES DISTRICT COURT 

[:I FOR THE DISTRICT OF COLDMBIA 

[3l_ _ - _ _ _ _ _ - _ _ _ _ _ _ _ x 

(41 

[5]IN RE: 

[6! 

I1 ’ GRAND JiJRY PROCEEDINGS : 

181 

l91 

I,,!__-___-___-_____~ 

Cl11 Grand Jury Room No. 3 

t121 United States Dlstrlct Court 

Cl31 

fi4i 

for rhe District of Columbia 

3rd 6 Consti:ution, N.W. 

(151 Washlnqton, D.C. 20001 

1161 Tuesday, June 16, 1998 

1171 The testimony of JOHN DAVID PODESTA was taken in 

[la]the presence of a full quorum of Grand Jury 97-2, impaneled 

11910” September 19, 1997, commencing at 2:16 p.m., before: 

[201 SOLOMON WISENBERG 

[211 Deputy Independent Counsel 

[221 Offlce of Independent Counsel 

[231 1001 Pennsylvania Avenue, N.W. 

1241 Suite 490 North 

1251 Washington, D.C. 20004 

Page 2 

PROCEEDINGS 

I: ; Whereupon 

JQHN DAVID PODESTA 

I: iwas recalled as a witness and, having been first du 

[ 5 ] by the Fore 

Re 

rson of the Grand Jury, was examin e? 

asn;om 

[ 6 1 testified furt&asfo~~N: 

I71 

[81 BY MR. WlSENBERG: 

[91 Q 

[IO! A 

Woutd you state 

John D. - David b 

our name for the record, please? 

odesta. P-o-d-e-s-t-a. 

i :: iwe have a 

MR. WISENBERG: And let me ask for the record, do 

uorum? 

1131 T 7-i E FOREPERSON: Yes, we do. 

MR. WISENBERG: 

I:!;in the grand .u 

Are there any unauthorized persons 

t161 Tt-/E??%psERSON: No, there are not. 

[171 BY MR. WlSENBERG: 

Q All right. Mr. Podesta, could you tell us what 

IZiyour position is? 

I201 A 

Q 

Im ’ the Deputy Chief of Staff at the White House. 

t::ibefore; is that correct? 

And you have appeared in front of this grand jury 

EEA 

3296 

John Podesta, 6116198 

[I! 

Page 4 

(J -you understand what that is, correct? 

i21 A Yes. 

Q And you understand that you have to tetl the truth, 

1:; that your t;stlrn~;~ IS subject to the penaltres of pequry. 

151 Q 

j 5 /those thinas further 

All right. You dont ’ need me to explain any of 

L 1. --~ 

191 3\ No: I understand. 

Q Okay. If theres ’ anything about my questions that 

I :i 1 you dont ’ understand, Ill ’ be happy to rephrase them. 

[I11 A Okay. 

[l?] Q All rght. I think we were - let me just say that 

[ : 3 1 its ’ been a while since you were here. 

I141 A Thats ’ true. 

Q And is it your understanding that we decided to 

I:zldelay your reappearance here until after executive privil 

(17 1 matters were kbgated. even though you were not a party “9” 0 

[ 19 1 the executive pnvi 

A Well “9” hat fitgabon? was carried on between the White Houses ’

t:~{Counsels ’ Office arid your office. 

Q 

I::{such a Ion 

Okay. Do you understand that that% why there was 

R 

delay? 

I understand that Mr. Ruff suggested to your office 

!::;thatit would be better - 

[251 Q Okay. 

i23i A Yes. 

1241 Q And youre ’ an attorney; is that correct? 

t251 A Thats ’ correct. 

Page 3 

Q Let me go over briefly then some of your rights and 

i:jresponsibilities as a grand uty ‘ witness. We went over 

r31them - I think Mr. Barger d. 

[slhere. 

Id - the last time you were 

151 A I remember that. 

[61 Q Pardon? 

171 A I remember that. 

Q All ht. And you recall that you have a right to 

I ii have an attorney ou “9. side and to consult with him as long as 

110 1 its ’ not disruptive to the grand jury process. 

r111 A Yes. 

I :: I] you 

Q 

today’ 

And you have brought such an attorney along with 

is that correct? 

1141 A ‘ Thats ’ correct. 

[I51 Q And his name is? 

[161 A Peter Kadzik. 

1171 Q 

A K-a-&z-i-k. 

Oka Give us that spelling again? 

[181 

Page 5 

A - if we can deal with it. I dont ’ think my 

I: jcounsel made such a request. 

131 Q Oh, okay. Thank you for the distinction. 

[41 A Okay. 

I z; hun 

Q I think when we left off last time, ou had just 

[ 7 1 the !i 

up with Mr. lsikoff of Newsweek and I thin 1: that was on 

aturday of the Presidents ’ deposition in the Paula Jones 

[ 8 I matter. 

[91 What Im ’ going to do is backtrack a little bii - 

[lOI 

Aa Okay. and then head back up hopefully chronologically, 

I :: { or in some kind of order. 

I want to go back for a little bit to the, 

i k:! Ambassador Richardson 

rl5lAmbassador Richardson. 

-your tesbmog havrng to do with 

ou had talk to us before about - 

(161 I think you said in Ma or June, before Ambassador 

[ 17 1 Richardson, that the & resident had asked Mr. Bowles to look 

[ 18 1 into hel in 

r193at the&h? 8 e House or at some federal agency, andMr. Bow& 

- possibly helping Ms. Lewinsky get a ob ‘ back 

rzolhad spoken to ou about it. 

And &en later on Ms. Currie had contacted you 

$:;directly about Ms. Lewinsky movi 

[ 23 I up contacting Ambassador Ria z? 

to New York, and ou ended 

son. Is that co rm& 

A Well I think the sequence is correct. I think 

I: : i that youre ’ putting a little more flesh on the Presidents ’

Page 6 

[ 1 ,conversation with Mr. Bow& than I remember at this point 

r21 

A Q Alj right. 

i: 1 Bowles had raised with me that the President had raised with 

I real y thank that my testimony was that Mr. 

i 5 i him that this person was unhappy about the way she had been 

[ 6 ] treated at the White House in a previous employment 

r 7 1 situation, and that would he look into that. 

I think 

1:; President asked 

our characterization was that the 

K. rm to get her a job at the White House or 

; ;;; another fedQsral;#;;.cy. 

A I don t recall that. If I testified to that, today 

i :: t I dont ’ recall savinq it, and I dont ’ recall that in the 

ilsjconversation. _ - 

I151 Q 

[16jto - 

Okay. _ So you _ re ’ saying “looking into,” as opposeu 

A Right. I mean youre ’ putting more into that 

I:iiconversation than I recall at jeast. 

Q Okay. And of course you dont ’ know - all you 

I:ziknow about the conversation betwee; - I take it, all you 

~2 11 know about the conversation between Mr. Bowles and the 

1221President is what Mr. Bowles told you; is that correct? 

1231 A That is correct. 

Q All right. Pardon me just a second while I 

tz:idocurnent here. Excuse me. Im ’ looking for a transcript t I! 

et a 

at 

OIC-Starr Page 1 to Page 6 
3297 

asA John Podesta, 6116196 XyIXi2l?l 

Page 7 

[ L 1 Ithought I had and Ive ’ misplaced. 

i 5 j situated. 

All right. Let me - I just want to get us 

Let me read to you from a transcrtpt from your 

f 4 1 testimony last time. 

151 A Oka . 

l61 0 AndYyou can tell me whether or not you still agree 

[ 7 1 with that or not. 

“Question: Do you recall any conversations or do 

i it i ou recall ever having conversations with anyone about Monica 

[?3llewinsky?” 

1111 “Answer: Yes.” 

(121 “Question: All right. And with whom, as best you 

; 13 1 recollect, were those conversations with?” 

!141 “Answer: I initially had a conversation, which I 

[15]cant ’ place precisely, but I wouki say late in the spring or 

[ 16 ] earl 

.a)l 

In the summer, initially wrth Mr. Bowles. Mr. Bowles 

[171sa1 to me that” - 

1191 “Question: This is 19977” 

1191 “Answer: 1997. And, again, I cant ’ - I cant ’

12 0 1 place a specific time frame on rt.” 

PII “Question: Okay.” 

[221 “Answer: But I would say it would be, ou know, 

[z 3 I maybe May or June. something ljke that. A b t goes on there 

: 24 I so It is all kind of a swish that swirls back out qurckty. 

[251 “Mr. Bowles said to me that in a conversation he 

-__ 

Page 8 

[I 1 had with the President that Ms. Lewinsky had come up. that 

12 ishe was a friend of Ms. Curries. ’ that she had worked at the 

[ 3 1 White House, and that she, Ms. Cunie. had been in touch with 

rrlher. 

Well Im ’ forwarding to it. I think that was a 

i 2 1 subsequent conversation.” 

[71 “Question: Okay.” 

“Answer: That she was a friend of Ms. Curries 

i ilthat she had worked in the White House, that she had been 

[ 13 lsent over to work in the Pentagon, that she was unhappy that 

[ 1: 1 that had happened and thought that she hadnt ’ been treated 

rlzlfairly in that ob move, and that could he look into it.” 

i::iBowles looktnto it.” 

“Ques Ion: And he ‘ look into it.’ meaning Mr. 

[:z{when 

“Answer: Yeah, because Mr. Bowles - I mean, 

- in that context, I think.” 

Cl71 “Question: As you understood it?” 

[I81 “Answer: As I understood it. I mean the -this 

t19lis not - the President will just often offload things to Mr. 

[2olBowies” - 

1211 “Question. Sure.” 

“Answer: 

i::iup that res 

- expecting that Mr. Bowles would divvy 

[ 24 Idont ’ take t!? 

nsibiiii. So I dont ’ know that that was - I 

at from that that that was personally that Mr. 

I 25 1 Bowles would look into it, but” - 

Page 9 

111 “Question: Oh, I understand.” 

I:;would 

“Answer: There was this person there that he 

ou know look into the matter.” 

A% ’ ht. Is that basically your memory today, 

I z i what Ive ’ gst rytakere also? 

(61 

[71 Q Oka . Let me also refer to another transcript. 

[El A Y( 

:i;with what 

Q 

I thin thats ’ consistent with what I just said. 

Yes I think it is. I think its ’ more consistent 

!I 

ou said ihan what my question was 

ow I want to talk for a minute about Ambassador 

:: i Richardson. That happened later, after Ms. Cunie came to 

13 1 you; is that correct? 

141 A Thats ’ correct. 

Q At any time when you were speaking to Ambassador 

i :z i Richardson did you 

(17 1 or the way he acted 9 

et the impression from anything he said 

hat he had already heard of Monica 

I 18 1 Lewinsky or heard of this person you were talking about from 

[ 19 1 somebody other than yourself? 

[201 ~A No. 

Q You testified last time to the effect that at some 

I :: ; point you bumped into him after you had mentioned this 

1231person. this friend of Bettv Curries ’ to him. and he had told 

i 24 j YOU his Office was 

After tha ? 

oing fo interview her. 

1251 time did you ever get any feedback from 

Page 7 to Page 12 

Page 10 

[ 1 lanyone about how that interview went or anything like that? 

(21 A I dont ’ - I dont ’ think so. I dont ’ recall 

r 4 1 &qether, tfouo% 

[ 3 1 etting an hrn back. I think youve ’ put two conversations 

i5i - 

A” l%%d to him o 

i76ifriend who had a friend, and did ni! 

inalty and said that I had a 

e have any unior ‘ level 

181 ublic affairs obs ‘ and he said he might. 

t9,%ell let me tollo;V up” 

An d I said 

- I dont ’ know whether I testified 

I 10 1 to thi; in the last conversation. but I couldnt ’ remember her 

ii 1 j name at the time, but said that I wouM follow up about it. 

L 12 IThat Betty was a good friend of mine - this was a fairly 

(13 1 brief conversation. He said. “Fine.” 

I think at some point, probably a cou 

[ : :; after that, he said - I ran into him in the P 

le weeks 

ha lway at the 

r 16 1 White House. and he said - and I cant ’ specifically recall 

117 whether he said, “I have talked to her,,” or “Im ’ gorng to 

(18 Italk to her our friend” - or “Bettys ’ friend... 

1191 ?I 

[ZOI A h%w Betty, so - 

(211 

A” &??the initial conversation, he knew who - I 

! :: ! told him it was a friend of Bettys. ’

~241 Q Right. 

L251 A So I believe that that was - thats ’ the 

Page 11 

[ 1 I conversation youre ’ referring to. Its ’ that second 

f 2 I conversation - 

[31 Q Right. 

A - in which he said - he said I think - and I 

I :ijust dont ’ remember whether he said, “Ive ’ hterviewed her,” 

[ 63or “Im ’ going to interview her,” or something to that 

r7,effect. 

iei 0 Oka 

I91 A I sai$ “Great.” 

1101 0 And after that you didnt ’ hear any feedback, as far 

i I I 1 as you know? 

[I21 A 

0 

No. .I dont ’ recalthearing any feedback. 

And do you have an 

I: :; the time or have you since learned h 

knowledge - did you have it at 

at the President ever 

I 151 talked to Ambassador Richardson about Ms. Lewinsky, in 

[ I 6 I addition to you talking to Ambassador Richardson? 

[I71 A 

0 

rm ’ unaware of that, if it happened. 

Did she - again, Im ’ not excluding an 

i:iiyouve ’ read in the pa 

tzolafter the scandal bro Re 

rs, okay? Dii 

r 

ou ever hear z%$ Eat 

e from anybody hat she did get a UN 

r211offeR 

1221 A I heard that subsequently in the press. 

[231 Q Oka . But aside from the press, you dont ’ - 

1241 

1251 

t ldon yt $eliive I - 

Page.22 

I11 A - knew that before I heard about that in the press 

[ 2 1 after the story broke. 

Q And I take it 

t:l]or didnt ’ hear abouiit before’ 

ou wouldnt ’ know whether or not - 

K e story broke. 

I dont ’ think I did. 

As you recall, I think you testified - you correct 

I:y; me if Ive ’ got tt wrong - that after you had the 

[ 22 1 conversahon with Mr. Bowles. you went to Ms. Cunie and 

[23 J said, “Have her call me if she wants to ” and she never did; 

[ 2 4 1 is that coned? 

I251 A Thats ’ correct. 

olcsii 
3298 

John Podesta, 6116l98 XMAXWW 

Page 13 

No, not that I recall. She said to me, as I recall 

[ 1 o 1 New York, she wanted to move to New 

I 11 ~atukl I oive her - vou know. coukt I aive her any ideas 

i 12 j about where to look for a job. - 

Do you recall talking to her - you said she 

you ask her why Momca hadn t called 

[I61 A No, not that I recall. 

Q Okay. Do you recall - I want to go back now to 

i:iithe May-June incident. 

I191 A Okay. 

~:$ompted 

Q The conversation you had with Mr. Bowles that 

I221 Wh 

ou to go to Ms. currie. 

en you went to her, did 

t23jyou in any way 

Ms. Currie indicate to 

- again, this is the earlier incident. Drd 

[241she indicate to you In any wa 

t25lMonica not come back to the bite House? 

that it might be best that 

-__ 

Page 14 

A I think she said to me she wanted to - she didnt ’

I: I lie the ob ‘ at the Pentagon. She said that to me. She 

[ 3 j wanted 1 o move on either to the White House or to another 

[ 4 1 agency. And she the circumstances that Ms. Lreberman 

tsihad sort of asked to the Pentagon. 

ther she said R was best if she 

It ldidnt ’ come back or - but there was a - you know. there was 

[ 8 1 a context of her feelin like she hadnt ’ been treated 

tsjfairly - that was - tha 9 

I 10 1 conversation - 

was my recollection of the 

ou know, could I look into it. You 

ed your message - 

she wouldnt ’ call 

Page 15 

IllYou. 

And with that as a preface -thats ’ a preface to 

I:lrny question. Did Ms. Cunie say, do, act in an 

[4 jto lead you to indicate that it really wouldnt ’ be zns 

wttyf; you 

[ 5 1 Monica Lewinsky to-be back in the White House area? 

A I dont ’ think so. I dont ’ recall that, you know, 

176;other than what Ive ’ testified to. I think Ive ’ given you 

[ 8 lthe gist of what I remember from the conversation. 

Q Okay. Would that have been enough -well, did Ms. 

t:~~Cunie ever tell you whether or not she relayed your message 

[ 111 to Monica Lewinsky? 

t121 A I dont ’ think so. 

I131 Q Okay. 

A 

t:!,;she didnt. ’

I don t think she ever told me whether she did or 

1161 Q Whether she did or didnt. ’

1171 A I kind of dropped it at that conversation. 

I181 Q Okay. 

A I mean I felt that Ms. Currie was - had 

I:zibefriended her she was kind of looking out for her. I 

I 211 her the opportunitv to have her call me. 9 

ave 

She never ca led 

i22 jme. I never thou -ht about it again. 

r231 Q O&ay. 

A Then she asked me again in October would I help 

I::;her. I had that one conversation with Richardson. That was 

OIC-StarrF 

Page 16 

c:]the end of it. 

Q Was the fact that she told you that Evelyn 

/;iLieberman had basically --Mrs. Curfle. Ms. Currie.’ The fact 

; 4 1 that Ms. Curne told you - Im ’ not very articulate toda 

r 

- 

r 5 1 that the circumstances of Monicas ’ transfer out - tha 

r6lEvel n Liiberman was involved in it, and the reasons for it, 

[:]wou x; that have been enou h to tell you right there that she 

[ 3 1 wasnt ’ going to come back 9 o the White House? 

A Oh I think I would have looked into it more if I 

[ ii 1 was - had pursued - if she had called me, wanted a job back 

[ 111 in the White House, and I wanted to pursue that, I guess I 

[ ;Z Iwould have checked into that. 

Q I mean, you didnt ’ even know until you talked to 

i i: i Ms. Cunie that - you know, the reason why, or a given 

c : 5 1 reason wh X Monica had been transferred out, correct? 

Thats ’ - the best of my recollection thats ’

jf76jright. I think I heard that from Ms. Currie. not Mr. Bowles. 

Q Okay. You get this message from the President 

i : zi through Mr. Bowles. 

[201 A Right. 

[21] 0 And when you go to Ms. Cuti to talk about it and 

“Your friend can call me,” you get this information 

Page 17 

A 

I: i Pentagon. 

I got the impression that she was moved to the 

Your characterization “sent packing” - 

131 0 Okay. Moved to the Pentagon - 

[41 

Aa Yeah. - because, amon 

i z; thought she was hanging around 9 

other thin s Evelyn Lieberman 

he West 

[ 7 1 that correct? 

\r$irig too much; is 

!31 A Thats ’ correct. 

! i z i 

0 All right. Drd that strike you as odd at all that 

iven the fact that the request is coming from the President, 

:: 1; 9% rough Bowles - I understand through Mr. Bowles - 

[12j A It didiit ’ at the time. 

[I31 Q 

A 

Oka!. In retrosrct - 

In re respect, I t ink that the conversation was 

i::isuch that Betty was a friend of mine, she seemed to have 

[I 6 1 befriended this youn 

[ 17 1 do a favor for her. S 3, 

woman, and I thought she was trying to 

e felt like she had been treated 

f 1 B 1 unfairly, and I just took it at face value and said, “Have 

t19j her give me a call if she wants to.” 

1201 Q Did you think ou would et acall? 

t211 A I dont ’ know. # & 

Q 

ou know,. 

Yes. And I think 

s a year ago. 

[~f~conversation. At least with Mr. 

ou satd that it was a brief 

E&v&s it was a brief 

t241conversation you had about this; is that correct? 

t251 A lt couldnt ’ have lasted more than a minute. 

Page 18 

(11 

2 %%y conversation with Ms. Currie couldnt ’ have 

I:llasted more than, you know, four or tive minutes. 

Q 

I :i is that correct? 

Youre ’ a good friend, an old friend of Ms. Cunie; 

.~. 

161 

i71 

A Thats ’ correct. 

Q Shes ’ a very intelligent lady; is that correct? 

A Mm-hmm. 

[ 19 I complex? 

A I dont ’ recall that if she did. I took this kind 

i :t 1 of at face value, that she was a friend of hers and she was 

[ 22 1 trying to help her. 

Q Okay. I think last time ou said that you - you 

I::;correct me if Im ’ mischaraderizing. I t t- Ink you said 

[ 2 5 1 something to the effect of that you assumed that the 

Page 13 to Page 18 
3299 

BSA John Podesta, 6/16/98 

Page 19 

[ I 1 request - the Presidents ’

“9 

uest of Mr. Bowles had come 

I? lthrough Ms. Currie because he President had mentioned to Mr. 

[ 3 I Bowles that this was a friend of Bettys. ’

(41 Is that a fair characterizatron 

A 

of your testimony? 

I51 

Q 

You could read it back to me, but I think so. 

161 Okay. Do 

7 

ou remember whether Mr. Bowles told 

i7y. - actually explicitly to d you, “The President told me 

[ 3 1 his 8s a request coming through Betty Cunie”? 

(91 A No. I dont ’ recall that. 

Q Okay. It was more along the lines of, “The 

1 :y 1 President raid k;ishf a fnend of Bettys, ’

[??I 

I131 Q 08.a~. Did Betty Currie when you want to her with 

(14 Ithis. did she mention at all when you hbd this conversation 

[ 15 1 with her - again, the earlier one, not the New York 

[ I 6 1 conversation, but the initial conversation - did she mention 

I I 7 ~Marsha Scott at all? iisi A I dont ’ think so. 

I191 Q All riaht. Did YOU talk to Marsha Scott at all 

izo jabout this topic? - _ 

[211 

I221 

“0 ,4Fsyt Monica Lewinsky? 

I231 A No, I dont ’ think SO. 

Q Did you know that Marsha Scott at around this time 

i :: i was also supposed to be working on getting Ms. Lewinsky back 

Page 20 

[ 11 to the White House, in late spring through late summer of 

[Zj97? ’

(31 A 

I41 Q 

I have heard that from a repotter. 

Okay. But did you know ti at the time? 

I don t think I knew that at the time. 

Page 21 

[ 11 no convepjQation;k;T Mr. Nash. 

[21 

A I don r believe I ever talked to Ms. Scott about 

[:iit. I had one more sub uent conversation with Mr. Bowles. 

[51 Q Okay. Is =7l t is the Hilley matter? 

161 A Yes. 

Q 

iii whether or not 

Oka . Well ’ talk about that in just a second. But 

ou X ad conversations with anyone else - 

[91 A 

Q 

io, I didnt ’ know anything about - 

You didnt ’ know anything about any other efforts to 

i:iiget MonicaALewd;Tky a job. 

1121 

I131 Q 

[ 14 I matter. 

Okay. Now, tell us about then the John Hilley 

I151 A A few days - 

[ 161 Presidents ’ deposition. ii 

ou know, three four days before the 

some me in that week before it. Mr. 

[ 17 1 Bowles once again ratsed Monica Lewinsky with me and said to 

[ 18 I me somethin 

I I 91 the conversa P 

- I cant ’ precisely recall the exact words of 

Ion. and, again, ii was uite brief - that - 

f 20 1 asked me whether I thought John HII ey, who was the assistant 

121 lto the President for legislative affairs and I think would 

~22 1 have been her supervIsor in the chain of - in the 

[23 ltegislative Affairs Office, was - would give Ms. Lewinsky a 

[ 24 1 job reference. 

1251 Q Who asked you that? 

Page 22 

III A Mr. Bowles. 

Q 

i; i make that request of you? 

Okay. And did he tell you what was causing him 

i z! somethin 

A To the best of my recollection I think he said 

that she had an interview in New kork 

9. 

- I think he 

t61- yeah, I hlnk he mentioned New York. That she had an 

[ 7 1 interview in New York or something, and did I know whether 

[ 3 1 Hilley could serve as a job reference for her. 

[91 Q Did he sa7y who was making this request beyond 

I 10 ~hlm. ‘ ” beins Mr. Bowles 

to 

him, 

illi A No. 

il ’ Q Okay. He didnt ’ mention that, “The President has 

[ 13 i asked me to ask you this ” for instance? 

(141 A I dont ’ think so. 

I151 Q Oka 

A I sai 8 

And what did ou respond to him? 

“I dont ’ know w K ether John would give her a 

[ :;; reference. 111 ’ ask hih if you want me to.” 

Q Oka 

i:i!did YOU recoqnize t 8 

Now did you know-at this point in time 

e nam& Monica Lewinskv? izoi - A- Yeah. 

Q All t-i 

I Z !these two requests 

ht. 

4 

And other than the fact that you had 

om Betty Currie - 

(231 A I think he may have - he may have prompted that - 

[24: : Q Oka 

I251 A - bu Y I - you know, I mean, I remembered her. 

Page 23 

Cl Okay. And I misspoke m 

I: i had these two previous requests the firs 1 

self because I said - you 

from Mr. Bowles 

r31the seamd from Ms. Currie. andyou ’ said Mr. Bowles nowmight 

[ 4 1 have prom ted you. 

[51 8th er than those two previous requests and the 

[?Fm 

pting. would there have been any other reason you would 

[ 7 1 ave known the name, Monica Lewinsky, at this time? 

[El A No. 

r:Z;unusuat? 

Q Did anything strike you about the request as 

A It was - ou know I et 20 re uests a day, so it 

i:iididnt ’ - it didnt ’ like - a r thetIme& a -some1 i&m 

113;off. I said, If ‘ you want me to ask him Ill ’ ask him.” 

Q But whether or not you et 20 a day or it set a 

t::;lightbulb off did ou consider it unusua In any way? 

1161 A’ I Jon? think I did at the !A. 

Q Okay. The chief of staff asking you about a pretty 

I:i;low-level person, and its ’ now the third time - 

I191 

I201 

“0 W@l, its ’ a.third time - 

A 

m a penod of six months. 

-over a period of six months which is a total of 

I::;- you know, Ive ’ spent eight minutes on this: 

[231 Q Okay. 

1241 A So it wasnt ’ like a big deal to me. 

(251 0 All right. You didnt ’ consider it unusual. 

Page 24 

A L dont ’ think so. I dont ’ think I thought it was 

I:; unusual at_the time. 

131 

I41 2 I?I!~& a few da 

IZithat? 

Q 

s tater I thought - 

All rig&. What II Id you do then as a result of 

A I had a very brief conversation with John, Mr. 

I~~t-lilley in the hallway as I recall. It was kind of - it 

[glwas a’ breakin u 

[lolinto him. I thin -9k.P I 

of a meeting or something, or I just ran 

was after a meetin or something. And 

1 I 11 I said - I think I prompted him. I sa 

I 12 1 Monica Lewinsky?” He said, “No,” 

k? “Do you remember 

I think. 

I said, “She worked for you. She was moved over to 

I::ithe Pentagon.” And that sort of tnggered some vague 

[ 15lrecollection in his memory. And I said, “Can you ive her a 

116ljob reference?” And he said - he said he couldn *P . 

[ 17 1 a personal reference - 

give her 

my recollection of the conversation - 

[ISI- couldnt ’ give he:,a+efse&ree -hedidnt. ’

I 19 1 really know her. 

I think he - I sort of recall that he described 

i:i;thern as “ships passing in the ni 

[22 J- as she was leaving, and that t a 

ht,” that he came in and she 

ere wasnt ’ much of an 

[231overlap. 

He replaced a man named Pat Griffin who had bean 

I::; head of Congressional Affairs, and I believe JO&I started in 

OIC-stair 
3300 

--. esA John Podesta, 6/16198 

Page 28 

[ 11 He couldntQhardly ’ recall. 

[‘I Did he have a glimmer about the Evelyn Lieberman 

[ 3 1 input into her transfer? 

(41 A I - you know, I dont ’ remember that. 

[51 0 Okay. 

[61 A Were ’ makin more of this conversation than the 

L Y 1 conversation holds. It was ? Ike a - took about a minute. 

Fe1 Q The uestions tve ’ asked you about these 

I 9 I conversations have 9 ar exceeded the conversations themselves. 

IlO1 A Absolute1 

1111 0 Yes. Pro \ ably many people feel that way about the 

[I? ~questions that I ask. 

I131 A JUROR: Excuse me, Mr. Podesta. 

Ll4l THE WITNESS: Im ’ sorry? 

1151 A JUROR: 

i i 6 i ever written? 

Do YOU know if that recommendation was . 

[I71 THE WITNESS: I dont ’ know. 

(191 BY MR. WlSENBERG: 

[I91 Q What did 

[ 20 1 “Well ’ give you an instiiu ty 

ou do after you - basically hes ’ saying, 

A 

anal.” which basically means - 

I::l]term like that. 

Yeah, I dont ’ remember if that was it. It was some 

[231 _ Q Right. 

I241 A And it was someterm he usedthat - 

[251 Q Meaning, “Monica Lewinsky worked here from, you 

Page 25 

[I learI 96. ‘ I dont ’ know when she leff and went to the 

11 I Pen 1 agon, but that he had met her. he kind of knew who she 

[31waS, but they had kind of passed In the night. So that he 

(4lc0uMnt ’ give her a personal reference. 

I51 Q Okay. Any other reason that he couldnt ’ give her a 

[ 6 ] p?mOnai reference 

I71 4 I-& just said he didnt ’ know her. 

131 

A Q I Ok98 sal to htm that - I told him why and said that 

[ ji;Erskine had asked me that she was gettin some job interview 

rlz!hesaid Well ‘ Icouldgive he!-heused!heterm-I 

l I I 1 in New York. And he $aid - a ain my bes recollection is 

! 12 Idont ’ remembkr ’ exact1 what it was - I think it was 

! 14 Jsomethin 

E 151like that s % 

like, “I coul IF give her an institutional reference, 

e worked here and these were her duties.” 

[I61 

I171 A” l%%. “Fine * and moved on. I mean, again, I 

[ 18 Italked to him like for*45 &onds. 

Q Did he say an hing to lndlcate to you that her 

I:~~performance had been less t x :. 

A 

an satisfactory? 

I got the distinct impression he didnt ’ really know 

[i: iwhat her performance had been. 

1231 Cl Okay. 

A That she was relative1 low level she worked in 

I:zithe East Wing, she had gone to the J entagon. Hnd that he 

Page 26 

[ 1 Ididnt ’ real1 I- he didnt ’ remember exadly the,circumstances 

[zlabout it. a hough I think that - that the auesttran of 

r>lwhether Evelvn had sarnethina to do _ wit .~ _Kii-ithiili maybe I 

i i j i&d sometl hit?g &I him about tfiat. because 1 knew that fact. 

[51 Q 01 

161 A So 

i7i 

cay. 

Q 

I was just t ing to place her with him. 

All r@ht. Abou r the circumstances of her 

i 8 j transfer, you meanT 

r:iior he mayA”ay:~~~k~!$~ 1 FsFg$ ~~~~~~~’ to hm ’

[1: lconversa ron - that, “She wen to thf! Pentavon. I think 

[ 12 1 Evelyn may have something to do wrth that. And he sort of 

[I 3 1 had some vague recollection of who she was. 

Q Okay. Did ou - it kind of segues into the next 

I ::i uestion, which you might 

4 

K ave already answered, but Ill ’ ask 

1161 anyway. 

I171 - A Oka 

Q Did \e say an 

[%tatement or a confirmation o ?’ what you hid said 

hing to you either b way of a 

x at 

[zolindicated that in any way, either because of her &orrnance 

rz11or anv of her actions while she was there. that it wouldnt ’

izzjbe appropqate for him to.write a recomtindation, other 

[23]than - youAve aA:~ady SaKl he doesnt ’ personally know her? 

(741 ..-. 

ti All right. 

Page 27 

A No, I dont ’ remember that he said anything in that 

I:iconvenation that - 

I: i you mentioned Eve yn to 

Q Qidrouj~.his~~~~~~~~~p~y~~~hen Im - 

[s Idont ’ remember if he mentioned tt to you or you mention I 

[6]tO him. 

171 A Yeah, right. 

[El Q Right. 

A I just - you know, I mean, this seems like the 

I :,iright ‘ time to say you know theres ’ a lot of water under 

[ 111 this bridge of - irn ’ trying td remember somethin that 

I 12 I happened five or six months ago about events w 8. I&I Ive ’ read 

ilsja lot about, 

x 

_ 

[141 

I tz i that fashion. 

I%% that I may have prompted who she was in 

1171 Q Okay. Do you recall him then saying anything like, 

[ 18 1 “I dont ’ know what youre ’ talking about. I dont ’ know 

c 19 1 anything about Evelyn Lieberman or anything like that”? 

I201 A He just - I think he had some ctlimrrter of who she 

izljwas. 

[221 

she had been there when he first at there 

I::;and she had moved to the Penta 

125leither nothing to do with, or virtua 9 ly nothing to do with. 

on in something that he % ad 

Page 29 

[ 11 know, x‘’ d;te l_995 until x‘’ date” - 

[21 1996. And these were her duties.” 

Q Oka 

!:Ianything like that? 7 

Nothing like, “She was a reat worker,” or 

s that your understanding o 9 what he 

[ 5 1 meant when he said that? 

A Yeah he said he couldnt ’ furnish his personal 

It; reference for her be&use he hadnt ’ worked with her. 

Q 

I ti information from him? 

Okay. Now, what did you do when you got that 

A Well I dont ’ think I did anything with it. Its ’

i :y 1 like it was overtake; b events. 

Q All righ r , okay. Is it Safe to say-if it h&%it ’

ii: i been overtaken by events 

[ 14 1 Bowles with the information. 4 ou would have gotten back to Mr. 

[151 A I think so. 

[I61 Q All right. 

A 

1:;; I dont ’ think he asked me to 

Because he asked me could he seyea;$ f reference. 

% 

et him to serve as a 

I 1 glsaid Id ’ check it out and get ack to him. 

0 Okay. Do 

i:yiMonica had actually alrea 

ou recall Mr. Bowles telling you that 

3 

[zzland that Mr. Bowles want 

listed Mr. Hilley as a reference 

to know if he could write a 

[ 23 1 recommendation? 

I241 A Thats ’ not my recollection of the conversation. 

[251 Q All right. In other words, you - 

4 

.&Ige.30 

I: i him 

A I dont ’ remember that he said that she had liited 

and I dont ’ remember that he requested that he write a 

I 31recdmmendation. I think that was your question. 

I41 Q Yes, either one. _ . 

A I stated what my recollection is which is, could 

Iz 1 he sefve as a reference, and I went out and a;ked that 

r7lauestion. isi ’ Q Oka 

[91 A And Y wouM have reported back, but - 

[lOI Q 

[I 11 interview - 

And your recollection was it was for a job 

1121 

[I31 

“0 I think so. I think it was for -. 

- as opposed to already having the job. 

[I41 A Thats ’ m recollection, yes. 

(151 Q Oka $ 

MR. WISENBERG: 

ardon me just a minute. 

Let me refer the grand jurors to 

rlrcl153,justforyourourrrnfomnman 

Ii 76:pa e - just for reference. in tefls of reference 

[ 19 1 top on that a e and the ve 

;+__&&$~+he. 

bottom entry. 

[201 Be hR. WlSENBgRG: 

[211 Q Do 

rzz I the very bottom en Y 

ou recall -thats ’ the second from the top and 

ry on 155. Do you recall whether or not 

~z31you told Mr. Hitley that youd ’ get back to him when he gave .: 

I z 4 I you his answer? 

1251 A I dont ’ - I dont ’ remember whether we just ended 

OK-Starr Page 25 to Page 30 
3301

asA John Podesta. 6116198

Page 31

[ 11 the conversation. I think he just - I think that was - I

(2 1 think Ive given ’ ou what I remember of the conversation,

[31 Q Akay. Have you directly or indirectly been in

[ 4 I contact with him since the story broke on the 21 st to try to [ 51get his recollection of that conversation?

(61 A I havent talked to him about it. ’

1111 A Thats a mouthful of a question, and I don ’ t even ’

[I 2 1 know if I know the answer to it.

Q

I:: I] to try to find out what his version of events

In other words have you dirzcttazi asked anybody

115 1 that first - what his version of that conversation was?

I161

[I71

t l_ttgk I need to -

llel A

ii9j

- have a file break.

Q Oka

i:Figrand ju

THE FOF!EPERSON: And I think its time for the ’

tzzlminutes.r

to take a break also. So why dont we take ten ’

1231 MR. WlSENBERG:

;;;;were’ readeEb$nNg;.

Okay. And well come get you when ’

Can you repeat the question that

Page 32

I I I you’ve asked me?

[21 MS. WISENBERG: [ 3 1 wait just a minute, too

Yes, and if the grand jurors can

for after the witness leaves.

I41 BY MR. Wl$ENBERG:

Cl

Ii; Hilteys’ version of events? And 111’ just go ahead and ask

Did you ask anybody, direct anybody to find out Mr.

(7tthe next question, which is, if the answer to that is no, has [ 8 1 somebody told ou what his version is?

(91 I thinl!

r 101 him. correct?

youve established you ’ haven? talked to

.~~.

Ill1 A I havent talked to him. ’

I121 Q Okay. And well come get you in about 10. 11. 12 ’

[ 13 1 minutes.

MR. WISENBERG:

Page 33

111 in the grand u‘ room?

121 TdE%OREPERSON: There are none.

131 Mr. Podesta ou are still under oath.

t41 THE WlTNE&: ’ Thank you.

t51 BY MR. WlSENBERG:

161 Q

[7]table.

Okay. I think we had a couple of questions on the

Isi A Restate the question lease.

t91 0 I was afraid you woul say something like that. *s

1101 The first auestion is. did vou ask anvbodv - I

ill jdont know if it ’ s the ’ fint question, ‘ 6ut 111’ try toget is ’

112 1 close as I can. Did you ask anybody to try and find out what

r13lMr. Hilleys memo ’

7

of this encounter was?

1141 A dont think so. ’

Q

No,

The other question is, did anybody tell you what f :z;hlr.HilleysAver+;;. ’ of the encounter was?

(171

Cl81 Q Okay. And who was that person?

[I91

1201

I211

2 JD;i;Tzr.Kadzlk.

THE WITNESS:

0 was it, please?

t221 Mr. Kadzik. Im sorry. ’

I231 BY MR. WlSENBERG:

Q All right. And do you know what - you certainly

I::; have a right to invoke the privilege on that, as to exactly

Page 31 to Page 36

Page 34

1: what he told you Mr. Hilleys version was. And are you doing ’

,2!SO?

01 A Yes.

Q Okay. Did you know an htn about the efforts of I,’ iVernon Jordan to assist Monica Lewinsrgl

t 6 j employment?

y In ocating any

I71 A No. Youre talking about before the ’ - before

t 8 i these events became public.

I91 Q Right.

I101 A

Q

No, I didnt’ know. I was unaware of that.

And since it became public. I take it. you only [ :: 1 know about it through the press.

1131 A That s correct.

I::labout it?

Q Mr. Jordan hasnt had any conversations with you ’

I161 A No.

Q

i :i isay that unless I indicate otherwise, all of my questions

What, if any, knowledge do you have - let me just

r~sjexcfude what youve learned through the press, through the ’

rzojrnedra, okay?

I211 A Thats a tall order. but ’ 111’ try to answer as best

[22las I can.

0

i::iof what our question is -

Okay. Just so youre clear, that ’ s my ’ - in terms

I251 A Yeah, I got it.

Page 35

111 - excluding that okay?

121 %hat if any knowledge drd you or do you have of

I 3 lefforts to aet a iawver for Ms. Lewinskv by Mr. Jordan or

None. I have no knowledge of that other than what

Pw 36

[I 1 are a-rate. And that he

12 1 lawyer In connection wlh tP

ot her a lawyer and took her to a

e

t3lconsider that to be unusual?

Paula Jones case. Do you

[ : ; basis to

A Well, I - as I say, I dont really have a factual ’

- to comment on that. I dont know what Mr. Jordan ’

161 has done for other people. I know Mr. Jordan.

171

i t%% he helps people. But I know less than what

ii;the prand iurors know about - in order to forrn an opinion to

io j judg5 that:

Q

:: i any efforts by an

Okay, I understand. How about - are you aware of

)s

body to get a la

13jwitnesses in the aula Jones case. y

er for any other

141

151

Aa I;int&,Paula Jones case?

A No: I dont think so. ’

r191qoes back three, four year

Q Do you have any personal kn&ledgeIties that were there.

i2oj-

[211

1221

A - think of all the~possibili...

Q Okav. Sonv I cut vou off.

,dge of any romantic

t and Monrce

i23j Do ;ou h&e any’ personal knowle

I 24 I or sexual rela ronship between the Prestden I ___.:__I_..m

OlC-Starr
3302

John Podesta. 6116198

Page 40

III A No.

121 Q Have you heard - again, excluding the press, but [ 3 1 pm- or post-scandal -

(41

; 2 j firsthand -wel??ondhand. ‘ third-hanj, nineteenth-hand of

- ave you heard, throu h hearsay, rumor,

I 7 1 any such relationship?

191 A Ive’ heard the President den it.

Q Okay. Other than the Presdems’ denial, have you

[ :ilheard ~ornAan~~y that there was such a retationship?

illi

Ii?1 (2 Have

ti:iknow.

A Other han the people commenting on r etevrsron, you

ou heard anything from anybod -

r ..

[I51 Q Okay. I consider that to be the press, the media.

[I61 A Yeah.

0 Has anybody said an

i:ii2tst or after, from which a reasonabC’

hfng to you, before January

person might condude

f I 9 1 that there could have been a rela~~nship,

[ 20 1 tomantic, sexual relationship between theg .

hysical.

resrdent and l-71 ~Monica Lewinsky?

As an exam

~f:~leaving the study toge her,” P somethin

le -just as an exam le. “I saw them

at, where

114 ~somebody hasn t made the statemen to you, but youve heard ’

[z5reither secondhand or third-hand of an event that could lead a

c I 1 call them events - the discussion with Mr. Bowles where he

12 1 told you about his discussion with the President. the Betty [ 3 1 Curne-Wilym;;hchF;n event -

r41

I51 Q and tht? Erskine Bow&-John Hilley event.

When-the scandal broke did those events concern

It i you when you looked back on those and tho

i E I and when “St”’ about those*

K

ou first heard about the story brea irtg?

Well when I - the story sort of broke over the

{ : z i course of three or fbur days, I guess.

Ill1 Q Okay.

CL21 A And when I understood that this was a matter under

Q Okay. Was there an appearanu? issue at the White

Page 38 Page 41

rson to conclude that there might have been a

Other than what I have read in the press, I know of

[:l-- Ive’ heard of virtually nothing factually, other than the

f 51PresidenYs strong denials personalty to me.

161 Q To you.

fl’ A Yes.

(81 0 Okay, all right. Well get ’ to that.

And. I take it, you never saw Ms. Lewinsky alone

[ 11 House when you worked there -let% just confine ourselves I z 1 now to the pm-January 21st time frame. And what ! mean by

[ 31 that is, were any speual measures taken to avord erther the [ 4 1 appearance of rmproprietis in connection with - and I mean [ 5 1 this as just a kind of pot&al issue.

Let me start over. Was there an appearance issue i ;i in this sense. That ou all took [ 8 1 sure for instance tt!at the P~~~~~~~~~~~~

(8 1 a situation where there woutd be rumors about affairs? ‘

A I think that with regard to any conduct we had in

[ :y i the White House, that was pretty far from our imagination.

I121

2 SOok%ont’ - if there were - I dont recall ’

I ::; having any special procedures established.

Cl51 Q

A

Okay. I want to make very dear -

i::jobvious

r‘

I mean, I think that there was - there was

[ 1 B 1 issue of

-im’ inflati~ some things, but that we had the

he congressional heari

il7jno. -

II81 j

1191 2 &%ydidnlidnt’ know what she looked like. I didnt’ I

Page 39

111 where thepi$llt was or had been?

I21

Q Did you ever see the President enter a room where

i:iyouthough MsR;.ewinsky was or was going to be?

:51

Q Did you ever see the President leave a room where

itiyou thought MS. Lewinsky was or had been?

A No.

A Right. -

Q Youve told us about these three ‘ events - 11’

with

rm3an,

rlgj19-thehaaringsoccurmdinI 4%

s on campa’ n finance from

rzojwe instituted a new and enhanced vetti I 2 11 was comina in to see the Pm&tent. whepmcadure to see who

ii; iapprdpriatefor ’ them to see hi.

aboc% in 1996, and

r it woutd be

1231 Now that wutd

Q

o to the questton you asked me.

Right Im&king ’ about like a Gennifer Flowers

~::&pe issue, and I wait to make very clear Im not interested ’

Page 42

[ 11 in whether or not you all thought that was a real substantive

12 1 issue.

(31

I drt’ ;mh;bout that.

Q W%ai im’ getting at - you know sometimes you have

f!ito worry about appearances, even if something isnt‘

(6 J necessaril

r

true. And so Im’ sa [ 7 1 staff, was hat somethin xing, as deputy chief of

rslyou weredepuvof this9

you a were concerned about when

of staff there at the White House,

[ 91 not putting the resrdent in a situation when, there would

r101even be rumors of impropriety?

A I must say I dont think, ’ in my recollection, it

1 i.ii really came up.

1131 Q Oka .

A And don 1 t think we had any special procedures for ’

i::ithat. I mean obviously there are - you know, the

[ 161 President is i public figure. There are all kinds of

117 jpolitical ‘ud ments one makes about that. But not in the

[ 181 context ha I P

Q

youre talking about. ’

Okay. Do you recall participating in any

i:z;discussions re arding Jones v. Clinton?

[211 A ?es. ‘

1221 Q

A

All right. What kinds of discussions were they?

1 had a couple of wnvenations wrth Mr. Bennett

i::;that were confined really to the timing of the case -

(251 Q Okay.

Page 37 to Page42
3303

BSA John Podesta, 6116198 XWW)

Page 43

A - that I had with him in order to have -just in Ii i order to be able to plan our schedule.

131 Q All nght. Those were just schedulin as opposed

[ 4 1 to political - partly political discussions, in terms oP

(5 1 timing?

A I think there were scheduling discussions. I mean,

I ,” 1 I guess, you know, I dont ’ - Im not drawing a distinction ’

I B 1 there, but I think there were scheduling discussions. I

[v I mean, we had to know if there was a trial, when was the trial

[ 10 lgoing to ha

8

pen, et cetera, et cetera.

Okay. No substantive discussion about the merits

1:: iof the case in those discussions?

[13! A Not in those discussions.

[141 Q a couple of times?

[151 A

1161 Q

i 17 j about Jones v. Clint3n?

A There was - I recall at least one occasion when

i::lMr. Bennett was going on television. I think that was

(20 isubsequent - Im suns it was subsequent to the Lewinsky ’

[z 11 matter. And we had a brtefin

r zz 1 session with Bennett at the V&e Housethat ’ IastJfor 20

if you will a kind of rep

.~~,

r23lminutes or so.

1241 Q Okay. To prep him. in other words.

I251 A To prep him for gorng on TV.

Page 46

?A>

a Well let me ust ask you some questions in case it ‘

/: jneeds to be set up for litigaEion.

I41 A Oka Cl AndYthat is, was Kathleen Willey discussed at all iz jduring this meeting?

I71 A I thank I cant get into the substance of this ’

[ 3 1 conversation.

I91 Q Okay. So also with respect to that specific

(1ojquestion. srnce that s wtthin the substance, you are ( 1 I lasserting .at the instruction of the White House attomeyI 12 lclientonwleoe.

y dont we hold that in abeyance ’ -

[251 Okay- Any other discussions about Jones v.

Page 44

I11

[21

I31

I:iSunday shows, or he was going on some show, and we had a

t6jround of what questions we expected him to get, because all [ 7 1 those questions were coming to the White House -

(81 Q Okay .

[VI A - and what his expected answers were.

[lOI Q Any other discussions concerning Jones v. Clinton

[ I I 1 that you rerllFemg wdh anybody?

I121

(131 Q

A

All right. Tell us about that. I had a si

~::~caseinthesummerof?9.’

ie discussion about settlement of the

1161 Q

1171 A

Okay. Tell us about that. Who had it with and -

Im not going to go very far on this, but ’ -

I181 0 Okay .

!:z!Ruff. ml

A Thepa

1211

I221

Ridpants were Mr. Bennett, Mr. Lindsey, Mr.

rse$ ant?.Pmsrdent.

A The oplc r was settlement of the Jones lawsuit.

t231 Q okay :

A

i::iprior to her switchmg lawyers.

To put thii in some time perspective, that was

Page 45

[II Q

A

Okay. What was the substance of the discussion?

That is where I need to stop because Ive been ’

1: i instructed by White House counsel that thats a privileged ’

[ 4 1 conversation.

ed in -what privilege?

A I mean, Im a senior adviser to the President. I ’

i :: ;give him advice.

[I51 0

I161 A

Okay. Youre not in the Counsel ’ s ’ Oftice.

But I m not in the Counsels ’ Ofhce.

[I71 Q Okay .

1181 A The counsel does at some level report to me -

Q Oka .

A -to he President. !

House has instructed you

1241 Q Okay. And ou wont answer any questions beyond ’

tzslthe general subject matter x,at youve given us. ’

Page43 to Page 48

Page 47

1 I 1 Clinton? I take it, one since your discussion with lsikoff

12 ] had something to do with that, that you talked about -

I31 A Oh, right.

Q Okay. All right. So lets leave ’ aside lsiioff

i:;because you had hung up on him when we left.

A Youve ’ J

I ,” i another conversation w??I Isrkof! in the summer of 97. ‘

ged m memory which is that I had

Page 48

cl]And I dont remember the details of ’ - but that it was [ 2 ] related to the Jones case.

And that - and I dont remember the details of ’

r21lweeks after that, I think, something in that time frame, he

rzzldid, in fact. write the Willey story with - and, you know, I

1231 know that youve heard from Ms. Steele because I happened to ’ ._

(24 ]be in the hallwa when she was here last time.

I251 Q Jo you think it was post - you know he was at your

OlCStarr
3304

BsA John Podesta. 6116198 XuAX,pRI

Page 49

[l Iclass -

iZ1 A

[31 Q

It was kind of in the middle of July.

Okay, pm-Newsweek publication, but you think post- I 4 I Drudge. or iust you had heard -

I51 - A If was post-Drudge.

161 Q Okay.

A Because what prompted me was, there was something

ii ion the Drudge Report that made me call him.

Q Okay. All right. Any other conversations with

I :li]anybody that you had on the Jones v. Clinton?

Cl11 A I dont recall having any other substantive ’

I ~zrconversations. I mean. there were obviouslv kind of. vou

i 13 j know, passing press inierest that may havecome ’ up; in- the -

[ 14 1 in copverratiqns around the White House, you know, what -

(151 how IS this gong to la

P z.

out, whats going to happen, how ’ -

I 16)you know, we were 00 Ing at a trial.

1171 I had conversattons about whether the

[lelshoukf go with the motorcade to Mr. Bennetts o ’ ff!

ress pool

ce on the

[191depo$&on. ’ but I wouldnt describe any of those as ’

1 zo 1 su stanbve conversations about the case.

I:: I invokin

Q Oka Other than the conversations that youre’

(z3lLinda I?ipp with a$body?

attorney-c tent pnvriege on, dii you ever discuss

(241 A Yes.

I251 Q Okay. Tell us about that.

Ill

[21

$ lS”uz to talk to my lawyer.

131 A Okay.

141 Q Why dont you ’ - when

1

oure ready to come ’ back, [ 51 knock and wait for somebody to open he door, okay?

[61

IY.

itness excused. Wtiness recalled.)

R WISENBERG: ! i ~witness has reentered the

Let the record reflect that the

f 9 1 quorum, dont we Madam ’ F

rand jury room. And we have a

oreperson?

I101 THE FbREPERSON:

MR. WISENBERG:

Yes, we do.

illi No unauthorized people present,

[ i 2 1 correct?

I131

Il.41

i:i!oath.

f171

fIRI

El91

I201

THE FOREPERSON: Not a one.

MR. WISENBERG: Oka .

THE FOREPERSON: d. Podesta, youre still under ’

BY MR. WISENBERG:

Q Okay. I had asked you the affidavit question

A You did.

$I .Tell us abqut !hat:

_.~ _--~-~.___._ -..-.._ -

Page 50

A Well, Linda Tripp worked at the White House in an

i : 1 office that actually at some level reported to me starting in [ 3 11993 when I had a diff&ent job.

I41 Q Okay.

15) A And when Mr. Nussbaum wanted her -I mean, you (6 Iwant to go back this far?’

11’ Cl I dont think so. ’

[81 A You asked me a very o n-ended conversation.

(91 Q Yes. Let me re+$rasc E question. Did you have

[ lolany conversatrons about Ms. npp Since you came back to the

[ 1 I 1 Whtte House a second time, up until January 21st?

A I dont think so. I don ’ t think ’ - I dont think ’

I::iso. I think she was kind of floating around in this Willey

[latstory -

1151 Q Oka .

1:,6ithat.

A - buY I dont remember talking to anybody about ’

1181 Cl Oka .

A And rhat precedes that. Thats sometime ’ earty on.

i:iilt started like Jul . Cl

i::iever have an

dkay. Did you discuss any affidavits of witnesses,

Y

discussion about affidavits of witnesses in the

1231Jones ca% o+zne;. Clinton case?

1241

1251 Q Tell us about that.

Page 51

A Very earl

I:f IBennett had said to me Y

In the Jones case, I recall that Mr.

hat they had a good a~davit -I

[zsldont’ know what the substance of it was - from one of the

1241troopers.

I251 Q Okay. Did he say why it was good?

__

Page 52

Ill A No. I mean, I think - it was not a substantive [ 2 1 conversatron. I wouldnt describe it as a substantive ’

M lawyerschedring. ’

[I71 0 day. Did you have any discussion about - do you

I 18 I recall having an

rlslbv Kathleen WIIL

discussion about any motion to quash filed

.~~. . v?

(201 A No:

L211 Q What, if any, role dii ou pb

f22 I

p”

litical prepping or prepptng of any z.ind of &

in kind of any

e President

1231 or his deposttion?

1241 -A None.

I251 Q Okay. For anyone else in their depositions in the

______ . ..-__--

Page 53

rllcase?

(21 A Not at all.

Q

Ii 1 that case as a media issue,

Okay. Were ou involved at all in how to handle

Jones v Clinton?

A Only - onty, as I say.insofar ‘ as were’

tzido our job and do other things other than dealing witht#9au a”

[ 7 1 Jones.

i i ; topic?

0 Okay. It woukl come up from time to time as a

!101 A t think it would - yeah, it would come up from

[I I 1 time to time as a topic. But I think @at we attempted - I

[lzlpean. I think the only canmttn~deatingwith

[ 13 1 it was that we were making sure we were trying to get f I 4 1 something done in the Whtte l-louse and try1

??

-the Jones

rrslmatter was handled by Mr. Bennett, and we ldnt’ kind of

I 16 I bleed into that.

[I71 Q Okay, as a substantive matter.

Cl81 A As a substantive matter.

1191 Q

izojother things.

But sometimes vou had to deal with its effect on .

[211 A Thats ’ corn&

0 Either as a matter of scheduling or as a matter of

iZ;media relations?

!$,:I talked to reporters

A M”~~,~~~~~~~~an,

Page 54

[I 1 often. That was mostly t&Currys’ job.

Q Dii

&

ou ever urge as part of your advisory duties

f:;thatthecasebese led?

A 1 think that goes to the substance of the

It;conversations that we talked about.

Q Okay, all right. Other than in that meeting, if

i ,” i you can answer it, just in tears of your job as deputy chief

{SlOf Staff?

A

r:z;remember e

I mean 1 had a view about that, but I dont’

[ 1 I 1 if we take tha“p .

ressingit’ other than - other than - you know,

( 12 lexpressin

meetmg out of it, I dont remember ’

that view.

1131. 8 Okay. What was that view? Again, Im not ’

[ 14 lmterested in the ex

c15lit should be settled.Ip

ression in the meeting. Did you think

1161 A Did I think it should be settled? I thought that

[ 17 Ithere was - I thought there was -I didnt think it ’ should

[le]be settled at an

[lslknow, thought tz

price. lwas~&at.tbePreslienl,you

at this whole thing was unfair, but I thought

rzolthat there was potential1

Q

damage from continuing the case.

i 5: 1Presidents’ de

Okay I &ink you testif& that on the day of the

p”

sit,&

[z 3 1 for the State

January i 7 1998 you were preparing

o the Union Address,’ is thai correct, doing

[z 4 1 some work in connection with the upcoming -

I251 A Give me the date?

Page 49 t0 Pa& 54
3305

Bsa John Podesta. 6116198 xmAx(lwlo)

Page 55 Page 58

Q Saturday, Janua 17. 1998.

A Yes. The day oft e deposition. x

[ 7 1 the West Wing of the White House.

[91 MR. WISENBERG: Does anybody care to see any maps?

I91 JURORS: No.

I101 A JUROR: We know exactly where it is.

1111 BY MR. WlSENBERG:

Q

r::~depasition~hat~~y

Did qou see the President before he left for the

I141

Q

::65iifyou know?

Okay. Where were you when the President returned.

(171 A I was in the West Wing.

I181 Q All riaht. Did YOU know when he returned?

i19j A No, n%t reci&ly.

0 Okay. believe you P weretellin 1: y llsikoff call. and that was going on, I take it, whr

us about the

9, he was

tzzlat the depriti0;es.s that correct?

1231

[241 Q Lets go back to the sequence we left off at when

t251you were here last time. You talked to Mr. Isikoff. he

Page 56

I 1 I mentions the name, Monica Lewinsky to you at some point in

tzlthe conversation.

t31 A Right.

Q Then you end the conversation. Before I ask you

t:;what happened next, Im’

[ 6]when you heard - youre’ 3,

oing to ask you what did you think

[ 7 I think

am-g about th;S big story. I

rdy

ou

tsl hea

told us last time to the effect that you first

about it on Saturday, but you subsequently learned that

t9jsome of the calls had been comm

:101 A P

in since Friday.

Q

R’ ht fromTimeagazme not from Newsweek.

O?ay. And then you call Isikoff ’ who you know [ ::; he mentions - I think ou said you asked him Do you have a ‘“ ’

and

131Starr ‘ - Ken Starr andyor a grand jury story?” And he said,

! 14 I “No, its ’ a Paula Jones storv.” and he mentions Monica at

tislsome point.

1161 A Rioht.

ii7j 0 IsThat -

1191 A I think the information that we had all garbled up

[19lwaSt201 Q Okay .

A -that it had somethi

Ig:&omething to do with grand jury and?!

to do with tapes and

ad

[23]Starr.

something to do with

Q

I:: i asks you about lf you know anything about Monica Lewrnsky; is

Okay. He tells you that its a Jones story, ’ and he

Page 57

tilthat correct?

[21 A Thats correct. ’

131 Q And what dti vou tell him that vou knew about

i 4 j Monica Lewinsk ?

A l& asked me whether I knew her. I told him I

!~~didnt’ know her, I dont know her. And he said ’ “Have you

[ 7 lever met her?” And I said Id’ met her briefly or!tce at a

[sjfuneral.

[91

1101 AQ And ell riilhL sard. Whose funeral?” And I said. “Its’

I 1 I j nobody you would know.”

Q

!::ithinking -do you realize-well ks obvious from

Right, right. Now you get off the phone. Are you

I 14 1 questions you realize who Mo&a Lewinsky is. Yy

our

ou dont have ’

I 151 to be prom

I161 R

ted any more than him just askwg. correct?

Thats correct. ’

Q

[ :i ;about three da

Because from your testimony I think it was just

t191Bowles. correx

s

?

before when you got this request from Mr.

I201 A Thats correct. ’

Q

i::ioff alarm bells?

All right. Did this concern you, worry you, set

I231 A It concerned me.

1241 Q Okay. And how come?

1251 A Well, he was now linking, for the first time in my

Page 55 t6 Page 60

[ I Imind. Monica Lewinsk to the Paula Jones matter.

I_! Q All rioh What did Y YOU do - what did vou do

i 3 j after you talked to him?

I41 A I went and saw Ms. Mills in her office.

I51 Q

A

Okay. Tell us about that conversation.

I went upstairs - I had previously talked to Ms.

If 1Mrlls and asked whether she knew an

I 8 IMaaazine reoorts. And so I went baX’

hrng about the Time

to her and I said. “I

[2o]Monica Lewinsk

[211 Q

A

dkay. And what did Ms. Mills say in response?.

I::;she would contact Bruce Lindsey who was with

She said that she would contact -1 $in&she said

[ 24 1 Bennett law firm where the depo&ion was t aking#ace-md

1251let him know that thats what was going on. and hat he would ’

[ 11 talk to Bennett about how to respond to Isikoff.

Q

Page 59

I:lcontact him while theyre at the deposition, Mr. ’ Ltndsey,

Okay. So she indicated she wasgoirg to try to

rslthat is.

I51 A Correct.

161 MR. WISENBERG: Im’ sorry?

I71 A JUROR:

calwas?

Im’ sorry. Do you recall what time that

THE WITNESS:

,r,Simaybe, on Saturda

It was probably mid-morning, 10:30.

El11 A JURO& Thank ou.

I121 BY MR. WISENBER&:

Q Do ou know whether or not she did contact Mr.

I ::iLindsey. get hoM o Y him? .

I151 A Yes.

1161 0 All right. And did she?

(171 A Yes, she did.

t1s1 0

A

Okay. And how do you know that?

She was - I think she talked to him on the phone

I:oiwhen ’ I was there and just basically said what I said yes

I211 Q Okay. Did she tell you what Mr. Llr&eyiold her

i22jin response? _

1231 .--~ A Thii was. I think. kind of a one-wav conversation.

Q Okay. But afterit was over did ’ sfie tell you -

iz:idid she relay anything that Mr. Lindsey had told her?

Page 60

(11 A No.

Q Did you team later at a subsequent time what stage

1: i of the Presidents deposition - what stage the deposition

t4lwas in?

Q Okay. Dii Ms. Mills appear to be concerned either

1:: i after you relayed the information to her or after she spoke

[I 4 1 to Mr. Lindsey?

A Ms. Mills is pretty poker-faced, so she never seems

t:Z~concemed. So -

1171 Q Okay. All ri ht.

tlelwere’ entering into a periodgofWhat happened next? I take it

I191 A She - I mean, she took the information. she passed

(20 1 it along, and that was it.

t211 Q

?

ht.

A

Okay. All ri What did you do next?

I went back o my meeting, tried to work on the

IZ;State of the Union.

0 Okay. When did you next hear anything related to

i::;the Monica Lewinsky matter?

OIC-Starr
Es.4

3306

John Podesta, 6116198

.._ . --.---- -.__- l___-___-l -

Page 61

_. ._ _.. ._~ _II__. _ ____ _“.

Page 64

II! A Later that afternoon.

12: Q

A

And what did you hear?

I dont remember the sequence, but ’ I talked to Mr. I: j lsikoff once more and I talked to Mr. Lindsey

151 Q All ht.

!F,! A And “3,t

Tell us about those &onversations.

i 7 : afternoon -

ey were about the same time. late in the

19: Q All . ht.

!X A - an 7I dont remember which was first. ’

I!01 Mr. l&off called me back, as I recall, to say

r I 1 sthev werent ’ runnino a storv.

il2i . Q Oka-. *

A And rsaid “Fine.” You know, it was like a - he

I i: ijust said that “We arent ’ mnnin ‘

Q ’ There was no su%

a story.”

stance to the conversation. other

I : i 1 than, “Were not going to run a story. ’ ”

A He - yeah. He said to me, We ‘ re not going to run ’

; : ;: j the story you asked ma about.”

1191 Q Okay.

A tie said to me. I said, The story I asked ou

i:!jabout was Ken Starr and the grand&

i 2 2 I said. “No. the storv I tokt vou about. 3t

and tapes.” Ancfyha

nd inj .Q Ok&y. -I said. “Fine.”

A I didnt want to engage with him, and I ’ didnt’

lg:/engage with him -

Page 62

[II Q Okay .

LZl A

Q

- and I just took that inflation.

131

i4i

He didnt ask vou anv ’ furttter auastions?

A No, not that I r&all. _

(51 Q Andwhatdii ouA

$zalled me.

I dont know ’ w!y~~dethat-1~11~~~

I31

[91

Q Okay.

A

?01 Q

I don t know why ha fait the need to do that.

Then tell us about the Lindsey conversation.

:11 A I saw Mr. tindse

12~office. I cant be ’ recise about Y

in the West Wing, I think in his

hat.

1131 Q AlPright.

1141 A

ain

It was after the deposition. I said to him -

was a fairl brief conversation - and I said to

I::$% ?&vdid’ it go’ke said “Fine They asked -they [ 17 @ii &k him about - they ask& him about ‘ Monica Law&sky.”

il81 2 $zti to ma And I said What did thay ask

i:iihiml’” And he said. “I dont know. ’ I was&t in the room.

[21 I

r221 2

Q

8% knew that thay had asked him

All right. Dii ha indicate he knew anything about

i::iMonica Lawinsk or who she was?

t2s1 A V& didnt’ have a substantive conversation about

Page 63

tIlthis

(21 Q

131 A

Oka . Any raasdn wh not?

I thrn4 at that point I ddnt’ want to team

IS ranching more than I already knew -

151 Q

A

And, of.qqurqa - . . . .

I61

Q

- or wed‘ be tnera all ntgnt.

Of course, by then he knew - by then youve’

iiialraady had this conversation where youre rela ’

r

ing to Cheryl

ts$lills the ori inal lsikoff conversation,, so - and hen hes’

[ 101 kind of donf rmmg ? that - not unfixing, but saying they

tilldid ask about Monica Lewinsk

Cl21 A That the Jones 7awyers asked about Mqnica Lewinsky.

[::;anybcXly’ know up to this point in

Q Right, riiht. Had pu dunng the meantime let

me abou thesa events

i

I c,jconcamt Monica Lewinsk that youve ’ tofd us about, the I Isjthings th?youre’ connedac?with?

A I dont think so. I don ’ t think I had a ’

i :j jcdnversation with - the only erson I mi ht have said [ tslsomething to is Ms. Mills, buPI dont thin ’ a I did.

Q Okay. Did Ms. Mills indicate to ou up to this

l:!ipoint in timz thatoshe knew anything about Ms. c‘ ewinsky?

1221

1231 Q I had a question, but its ’ escaped me now.

I241 f 25 ICurrie?

Had you spoken up to this point in time with Mrs.

II1 A No.

(21 Q

r~lthat day?

Ail right. .Do you rac.aU if she was even there

i :i answer.

A I dont ’ recall. lf I couid - let me restate that

I dont know whether ’ she was thare that day.

161 Q Okay. You had not spoken to her up until that i 7 j trme.

181

191

6 l;Et speak to her that day.

IlO1 A And don Y t know whether she was in the White House ’

[1110f not

Q Okay. What, if anything. did you know - by the i k I time of the sacond conversation with Is&off what if

~~~~~~~~ didp know about lsikoff haT:placed a phone

tty urria a day or two before, as mng her some ( I 6 1 questions about Monica Lewinsky?

f171 A

El81 Q

I dont think ’ I knew anything about that.

Did you ever know anythi about that?

I dont think so. ’

Page 65

111 Q Okay. So you cant ’ enkghtan us on that event?

12) A No.

Q

~ZjMrs. Currie.

Or on an allagad OT possible lsikoff phone call to

151 A No.

[61 Q Okay. What next? You talked to Etruce Lindsey [ 7 3 sometime: thEiaft$moon after the deposdron.

181 Q &ats your ’ next interaction with the Monica

[ izi Lewinsky matter?

Ii11 A The next morning.

Q All 1 ht. ~Tettwsabwt+at, I : : i do that - did you ta“;t,

M-me*-befurc_pw

to the President at all that day

ri4iafferhegotbac)rfromthadepo?

ilSi -A No .

1161 Q

ti;ijthe 18th?

Okay. So what happens than the next day, Sunday,

A f got a call at home fairly early in the morning

[ $! from Mr. Stephanopoulos.

1201 Q Okay. And how do you define “fairly early” for us?

f211 A 990.

1221

1231

1241 f251

Page 66

rljWhite House -

121

131

AQ okay .

- he was about to go on the ABC show where hes’

f4m--

I51 Q

A

This Weak or something?

Yeah This Week. Hes a regular on a Sunday ’

I: f He has a contract wkh ABC.

181 Q Okay. Tell us about that conversation.

A He said “Have

f:iiReport?” I said, “No.He“‘ sa~h~~~~~~h~~dge

1 I 11 read it to you.” Or I think he said - ma

1 ~;charactenzed it. I dont ’ know - I dont’ ink - Im not ’

tlsjsure he had it1141 Q Oka.

i : 2 I spa&call

--buy he had heard it. I cant remember ’

the conversation

i :i lout the ni

ut that there was a Drudge Report that had coma

(Islthat said ii, .

ht before I think&rmaybaaady~-themamiag.

at lsrkoffwas working on a sto . I dont’

(m1 remember whether it namad her or not, bur that rt was a, you (211 know, Paula Jones story, a scandal, intern, White House, sex

Sh

LZZIYOU know -

I231 Q All right.

A

t::jabout this?”

-the Gestalt, you know. So, What should I say

LOW.

0IC;Starr Page 61 to Page 66
3307

John Podesta, 6116198

.- __ ._ . - ..----- ----- -

Page 67

Ill , 1, Bout +,.$$, An %3M. And he% asking you. “What should J say

;; ;----‘...-A ‘ “What do

I 4 I if this comes UD on the

ou know? How am I going to react to this

sxow?”

isi Q

I 6 I early Drud

SO‘ you dont recall at this point whether this ’

r7iReporton&e

e - this is the first mention of the Drudge

Lewlnsky matter that you can recall, this

[e$?%ephanopoulos conversation. correct?

A Thats the first that I can recall. It ’ s the first ’

[ f~~me&#n. I do recafl this and i?s‘ the first me&on.

IllI Q All right. And whether or not that re ‘ art

[u 1 p?antionedLewinSk

I 131 rt was about LewlnsI;‘

is it fair to say that you thougf:t that

y. that it mentIoned an intern or

[ 14 f whatever?

1151 A Yeah.

(161 Q Oka

d

. AWhat did ou tell him to say?

Isa’ - I said tha! -I think I told hwn Id by ’

f:iltogetChe Itocallhim.

1191 8

fZD! A 1% %%re I accomptished that. I dont think ’ t

121 Idid. I- you know, that I hadnt seen the report, ’ I

[22]+1ldnt’ give him any factual, you know, response to it, and

f231rSt -“r; ( 24 I hrs IS

-l%e only way you qn respond to it is to say

rudge, hes a ’ ~mor-monger, doesnt know anything ’

125 iabout the details of this, and you cant believe what you ’

Page 68

And did he say something to that effect?

Page 69

[nzlwas

(23 $@. I%

oing to happen, Mr. Bennett needed to deal with it, and

ills was getting in touch with Mr. Bennett.

I241 Q Okay. Youre not anticipating at this time that ’

I 2 s I youre going ’ to be a primary person dealing with this

I

/

,

I

,

I

I

,

/

!

I

Page 70

( I I scandal?

121 A Thats ’ correc!.

f31 Q Because -- why? You dont do that kind of stuff, ’

I 4 I or because you already realized your potential as a witness?

I51 A

fsimatter -

No. because I thought of this as kind of a Jones

I71 Q Okay .

A

i t I keeping in Mr. Bennetts office an ’

Q

-whti we basic&$ had ~n~*~~o~~~~ut

out of the

!I01 Okay. W&at happens next in temx of your

11 I 1 interaction with this event?

f121 A

!I31

I dont think anything else happened on Sunday. ’

0 All ht.

i ::i Bennett.

A I thin Ms. Mills was going to follow up with Mr. s

And I dont think there were stories that were ’ -

[ 16 1 there were no stories. I think, written off of this.

Page 71

Ill Q All right. Did anyone tell you not to go into the I 2 I White House that dav?

i3i A No. ‘

!:lSundav?

0 Okay. Do you usualty go into the White House on

i6i * A I usually dont ’ 0 to the white House on Sunday.

171 KS usually my one day I stay 3,ome.

1st Q Okay. Then that takes us to - let me ask you

rslthis. At some point in time during this time period between

[ 1 o I the date of the deposition and The Washington Post story -

[ll~that wouUAb” Jganhz;7th through ZlstCl21

11.31 Q - did so&bod

~14 1 trying to get employment for My

tell you that Mr. Jordan had been

A

s. Lewinsky?

I dont think so ’ I think I learned about that -

!:%vell, I think I teamed about thht the day before The Post

rr7lstory fFom The Post re

1181 Q Okay. k

rters.

ot from anybody in the White House.

[I91 A Coned.

t%eamed

Q All right. Do you know whether or not - have you

at any time whather or not Mr. Lindsey knew that Mr.

tz2 1 Jordan had been trying to get a job for Ms. Lewinsky?

A If 1 understood the

!::i know that Mr. Lindsey knew that h4

uestion right it was dii I

r.

fzslher a job?

Jordan wab tryini to get

Page 72

Q Well, have you learned at any time that Mr.

I: { Lindsey, lets say ‘ - lets assume you ’ re coned and the ‘

[ 3 I Drudge story broke in the eally morning hours bf the 18th.

f41 A Right.

Q That prior to that time - have

jz!tiime that prior to the 38th Mr. Lindsey knew hK

ou leamed at any

r. Jordan was [ 7 f trying b gz a ~;o;;~ng to help Ms. Lewinsky get a job?

I81

f91 Q No?

1101 A I dont ’ unde~tand -I think the answer to that is

rl7iDrudqe -

imj - A I don% #+inkso.

f:ifMs. Mills.

Q Okay. And how about Ms. Mills? Same question for

i21i A I didnt place Mr. Jordan ’ in this story, so I dont’

f22lthnk -think that.

I231 Q

A

But he ot placed as soon as it broke.

Sy The

[::lPost on the Tuesday.

Bost. At least I knew about it from The

-.-_ _ ,.._ _ ~... _ ~~~

Page 67 to Page 72
3308

BSA John Podesta, 6116198 xurylYl3)

Page 73 Page 76

111 Cl Assuming that somebody has told investigators -

othetical -

Okay.

-\uasi hypothetical. .- Assumin that somebody has

15 I told investigators t at R was no secret in the &ite House

16 1 or in certain parts of the White House that Mr. Jordan was [ 7 1 looking for a ob for Ms. Lewinsky. is that something you ‘ re’

I A I in a oosition Io affirm. denv. or iust cant ’ soeak to?

[I : briefing with the President, but he was meeting with Prime

12 ; Minister Netanyahu.

(31 We have what is described as a ool spray. That

[ 4 1 means all the reporters come in and the [ 5 1 they shoot some film and they can shou

7 c&k pictures and

161 think we had the same basic Ian.

questions. And I

Q And does the6resident - youre ’ actual1 Iii I should back up to the 191h. Were you present when ti- maybe

e

1 T J 1 President was being briefed in any sense?

[lOI A I don t think so.

Cl i :: 1 being briefed?Okay. Were you present on the 20th when he was

:13: A I mean, I dont have a specific recollection of it. ’

(14 ! but it would be a normal thing for me to be there.

Q Qka . Do ou recall at that point any substantive

I:iidiscussion by him. rke. ?

L 17 1 like that?

“I& story isnt true, ’ ” or anything

A No, not - not on - I just - thats why I don ’ t’

I :“, i know whether I was in the briefi

Q Okay. Anything XoFbe 20th. Tuesday, the

:::;2Oth. about the scandal?

A I learned - I think the only new fact I learned

I::lwas that - back to our friend, Mr. Drudge - Mr. Drud e had

[24]re oned that Ms. LeWinSky )rsdtameintolhe%?it~

R .‘

&use

[25 1 a er mldmght on numerous occasions. I think.

L-i .

[Yl A I wasr;t‘ awii&of it. ’

I101

[III i sOo”%ont’ know what it means to not be a secret. 1 Cl All right. Have

i :t 1 anyone was aware of it before r

ou subsequently learned that

he Drudge story broke, not

(14 lfrom the press, but from any source other than the press?

I151 A

Q

M only knowled e about that is from the press.

Okay. All right. %nd I take it that means no

i:;lone has even confirmed it, somethik that ydu initially read

[ 18 1 in the press.

I191 111’ ive ou an example. You read in the press,

r2olas an examp?e My.s Mlls knew that Vernon Jordan was looking

12 11 for a job for Mdnica Lewinsky even before the 18th and later

r 22 t YOU ask Chervl Milk. “Is that true?” and she says, %es. ‘ “

i23j- In othei words; what youre’ sa [ 2 4 1 complete knowledge on this topic is rom the press. Y

ing is, yoljr

I251 A Ive got to tell you. I ’ m not doing fact-finding ’

Page 74

[ 11 here. So Im not going around asking people ’ -

[Zi Q Right.

A -what did they know, when did they know it. But

t : i my knowledge is from the press.

IS1 Q On that ooint.

isi

[71

A Yes. '

Q Probably on some other points, too

181

[Yl

(101

llll

A Yes.

0

A Its arbn Luther Km s Birth ay.

Q

qkz. Now, Mond?;,mor!-iin+ whats happening then? ’

.~~. What are YOU doina

i :: i in m

A I had a -I-always fiave a communications mt

d

office and even though It was a - since it was a [ 14 1 hol ay, I think some people participated by phone. But I

[ 15 1 was in the office, had a meebng.

I161 The President was going to do a service on Martin ( I 7 1 Luther Kings Birthday. We dealt with that event, who was ’

(181 oing to staff it. I cant remember who went with him. ’ I

1191

rzal!&f. Ant with him.

ink It was &latthews, whos the other deputy of chief of ’

sting

.__~~ .

I211 Q Oka

A I ha(r

%iClO. so I know I didnt ao ’ - I didnt ao with the President. ’

a separate meeting wtth the head of the AFLi;;jAndthe ’ few of us whci %eredealin -with what was

[zslvis-a-vis the press, et cetera, I thin&

oing on

understood tha this 9

Page 75

[ 11 Drudge Report was still hanging out there, even though I

[zlthink no news

AnB

apers had icked it up.

I didnt ’ briefthe President that morning but

I:; I think that we decided that the right answer was just tb

[ 51 kick the question to Mr. Bennett.

[61 .Q Okay .

ii; Drud

A If the President was asked by the press about the

e Report to ust have him respond to that ‘ - he should (91 refer he question 9 1o Mr. Bennett.

I101 Q Are

[lllanybody on the l9tz

ou learning anything new factually from

?

Cl21 A

Q

I dont think so. not on the 19th. ’

i ::i factual1

And I take it, you hadnt learned anything new ’

[ 1slYouve’ r

beyond wiat youve told us on the 18th also. ’

old

[16]tight?

us everything you know factually at this point,

[I71 A Thats correct. ’

Q So theres a discussion at some point ’ “Lets kick ’

I : ii it to Bennett if hes asked, ’ ” when he goes out for thisevent ’

120lrelated to Dr. King.

I211 A

Q

Thats my ’ recol+lection, yeah.

i::iinteraction you have.

All right. What s the next Monica-related

i::iday.

A

And,

We kind of go through the same scenario the next

again, I dont remember whether I was in the ’

Page 77

111 Q Qka.

I:isaid.

A I don remember exactly, again, what the report r

Q

I Z i cut you off?

Is there a sense that things are getting - did I

A

Im sorry. ’

And I said - I believe I said to Ms. Mills, “We

17”; ought to be_ able_ to knock that down if thats not true. ’ ”

181 Q Oka .

[91 A And rthink she told me it wasnt true. ’

I101 Q Okay .

1111 A They had no records of it being true.

[I21 Q

1131 A

That she had come~aftermidwi@t?

0

Yeah, several times after midnight.

And meanwhile is she telli

?

you anything new, i :: i anything that she knows about -is sti tel In& vpu anything [ 161 new or OM that she knows about Ms. Lewins y .

[I71

1181

A No.

Q Is anybody doing that?

i19i A No. - - -

1201 Q

A

In other words. youre tracking the story. ’

Tracking the story, h

t::! B.S. and its going to go away, and ’ %

ing its all, you know, ’

[231Rep&t.

at its only a Drudge ’

Q Any pending sense of worry about this as more

i::;details emerge?

Page 78

Well, no more details had erne ed, but -

Well, at some point he 9s‘ arts using her

[51

[61

AQ s*qe, ti~ov recall.

- I on t remember that. I dont know. ’

[71

(81 4 YOokuhave to tell me.

Q Okay. Tuesday, the 20th. I think is - were up to ’

1 :ziTuesday. the 20th.

1111 A Mm-hmm.

Q The story comes out Wednesday, the 21st. in the i ::; hard copy Post.

[I41 A Right.

I151 Q

il6jeditiOn.

And presumably at some point on the Internet

[I71 A

[ IE 1 thats true. ’

Right. Oh, I dont know that ’ - I dont know that ’

El91 Q Okay. But certainly on Wednesday it comes out.

[201 You were talking before about somethin (211 from a reporter. I cant remember right now what ’ IQ.

you heard

IS,

(221but-

.A Yeah. The Post called in for a response to their

i::istoty that they were running on the 21st.

I251 Q Okay. When did they call, on the 20th or Zlst?

OIC-Star r Pa@ 73 to Page 78
3309

ESA John Podesta, 6116198

111

Page 79

A On the 20th.

Page 82

i2i Q Oka

A The &ost was hunting the story on Tuesday that

i :!would publish on Wednesday.

I51 Q Okay. And who did they ask for a response?

161 A

171 Q

They were looking for any official response

Oka

IBI A I thinY,

And did they get one?

Mr. Bennett res onded to it.

t91 Cl Oka Do you rememEer what he said?

101 A

Q

No. mean, Y I think he -

111 All ri ht. You still havent had a substantive ’

12 Idiscussion with the Bresident about this, correct?

I131 A Thats correct. ’

1141 Q How about with Mr. Bowles?

A I think the first time I had a discussion with Mr.

I :~~Bowles was after the -I dont think we talked about the ’

; ;;) Drudge Regonbkay.

A I don t think we did. I dont remember doing it. ’

~:~~I think, though, The Post story was significantly different

I 2 I 1 in one regard, which was The Post put the Time Magazine and

t22jthe Newsweek magazine story krnd of together.

The

r

satd that this was being invest’

is:,Starr ‘ that - I hink they - I think that was the !?

ated by Mr.

rst

[ ;s 1 time i learned about the Vernon Jordan issue as well.

they

111

Page 80

Q Oka

A But tXat Mr. Starr had gone to the Attorney General

i:iand asked for an expansion of jurisdiction at that point

14 texbansion of iurisdiction. so that this was not Dart of the

i 5 i St&r investiibtion.

Q Okay. It was much more serious when The Post story

176;is published both because of the new facts some of which

181 ouve’ elucidated. and because its published in The Post on ’

[Y 1r he front page as opposed to the Drudge Report.

1101 A

[Ill Q

Both of those thin s are important.

[I21 A

Okay. Did you tak to -

And think talked to Mr. Bowles about that.

1131 Q Okay. And that would have been on the 21st.

I ::i repotter.

A Yeah. I dont recall ’ actual1

I think that the people who dealr.

talking to a Post

116 1 came and told me this.

wdh reporters

1171 Q And that was on the 20th. correct?

1181 A On the 20th.

Q Okay. Do

~:~~9owles, whether it would K

ou remember when you talked to Mr.

ave been -

(211 A I think this wouM be late in the afternoon or

rzzleartv .~~. _ in the evenino.

I231 Q On7

1241 A On the 20th.

[251 Q Okay .

111 A I think.

[21 Q Okay. And tell us what you remember about the

[3lUDnvenatiin.

[41 A I told him what The Post was going to write the

rs~next day,._and that, you know,

r61was stanrficant. senous. a bat

it seemed, you know, that this

.

- Q

d story.

Okay. And did you all talk about in any way the ‘

Iilfact that you had thts intersection, so to speak, you and Mr.

tg1Bowles. atps;%;,e intersection connected to Ms. Lewinsky?

I101

[Ill Q And tell us about that

1121 A He said to

--_-. _..-_.

.~~. a

tl3jhad really talked about thirzv<r

ain

w

I think - I dont think we ’

e weekend. I think he

Page 81

[ 14 1 said to me something to the effect of, “I dont think we did ’

t 15 1 anything wrong. Didwe do anything wrong?”

1161 Q Meanino vou and he.

i17; A Me andhim.

[I81

i:i;about it.”

AQ And Okay. srd, “No, but we probably shouldnt talk ’

I211 Q All right. And did you talk about it after that?

[221 A No. -

1231 Q

124 1 bu

And when you say “it.” you mean the story - the

t25]allr%id?

eoning story in general or the particular things that you

Page 79 to Page 64

Cl1 A The latter.

Q

i: idone. What did you talk a

Okay. So oil didnt ’ tatk about what you aH had

[ 4 ljust in general?

Lut with respect to the story,

[51 A I think that -you know, it was a stunning story. [ 6 1 I think its fair to say. and that we didn ’ t’ real1

17 Iwe were going to deal with it. other than try o get Mr. Y

know how

I 8 ~Bennett to deal with it -

i9i Q All ri ht.

[lOI A - an% hope that there was no substance to it. 6ut

I 11 lat that wint we reallv didnt know. ’

1121 ’ Q Alj right. Its fair to say that you got a tip ’

I I 3 1 that whoever had the call with The Post reporter had the

[ 14 J eneral outlines of what The Post was going to be reporting

,151we next dav. . .

i16j & Yeah. I - you know, I put Mr. Jordan - I dont’

[ 17 1 know whether I knew Mr. - I mean, that I might have read the

rlelnext dav.

i19j _ Q The JordanA

!:~~investiiatina this. was. I think. al tn The Post s or-v the

But the Ken StanTece, that ther were

izjnextdsy. ” ~’

I::lJorrJan

Q Okay. Youre saying ’

P

art the day before the 20th.

tz51of it on he 20th.

111

Page 83

A I -ust dont remember ’ -

r21 Q dka

A if that was something that they had told us

i: ;about or hadnt<old ’ us about.

[51

I61 AQ

[7]might give

gk&Le The Post will ask for a reaction and they

I B 1 whole sto

you threequarters of the story, as opposed io the

6‘

r:i!Mr. Hilley? You didnt say like, ’ qy the way,, Hilley s

Sure. Okay. You didnt tell him ’ anythin

9

about

no

[I 11 going to wpha;. ‘ letter of recommendation ?

1121

Q Okay. What happens next? Thats on the 20th. Any ’

I :: {other thing you can tell us about this in general on the

t1512Oth?

A I tried to find Mr. Kendall Mr. Bennett Mr. Ruff.

;:76;Mr. Lindsey, and Ms. Mills. I think I talked to virtually

c I 8 I everybody.

[I91 Q All ri ht.

A I sai8

Let them know2

I:! I couMnY let this story run without

that we had to react to The Post because we

any

I221 Q Okay. Did you all react, bor#$~?!?rt&&?

I231 A

t241 0

Bennett I think, reacted, as I recall.

Okay. bo you recall what he said?

[251 A I - you know, I think he gave some general denial,

Page 84

111 but I dont remember ’ -

I21 Q Oka . What about the -what next?

I:iof us felt.

A I think he said, “I smell a rat,” a sentiment many

::;20th?

Q Okay. Anything on the 20th. anything else on the

A

iii the evenin

That was kind of late in the afternoon or earty in

[ 9 1 had talked9

so we - essentially, that shut - once we - I

o a round of the lawyers, somebody was

[lotget back The Post, and I think we conduded that Mr.5e

oing to

nnett

[ 111 was the

“9

ht person to get back to The Post.

(121 t was over until the next day when we knew -

[I31 Q Okay .

[I41 A I mean, I went home and went to bed.

1151 Q Okay .

1161 A Got up in the morning and read The Washington Post.

All right. Again, no ones giving you any new ’

All right. On the 21st The Post story comes, all

f211 heck breaks loose. correct?

i22i A Thats correct. ’

E2lst?

Q What happens -whats your morning like on the ’

i25j A Gloomy.

nGStarr
3310

BSA John Podesta, 6/16/98

.~

XMNu15/15)

Page 85

[II

2 %!%ci our regular morning meetings.

15 i people really werenY sure how to deal with this, how to

I think the

f 4 1 react to It.

I51 Q Okay .

161

171

$ A&v$ztt in to see the President.

I 17 jthink we said anything

[ 18 1 this specifcalty to Mr. Bow&. He said, “Enkine, I want

113 1 you to know that this story is not true.”

[201 Cl What else did he say?

I211 A He said that -that he had not had a sexual

[ 22 1 relationship with her. and that he never asked anybody to

f23lhe.

!24]

I251

Q Oka . What else?

A I Ihit& thats all he said. ’

Page 86

Q Oka . What was the response of Mr. Bow&.

Iii yourself, or Ms. &hews?

A I think we were trying to kind of - you know, I

I:l]think was an intense or a tense penod, and we were just (5 1 byin

Ii!

to, you know, kind of, I guess, buck all of our I 6 ISDI s UD a little bit. all four of us. not iust his in

i 7 j particular. ’

.

I91 Q

A

Ail iht. Who said what?

I don remember. I mean, I dont think anybody ’

r:ilsaid anvthing. I dont ’ know that there was all that much to

illjsay. _ -

Q

I::lto handle it?

Did anybody give him any advice about how he ought

1141 A I don? think at that point in that meeting we did.

[ 151 I think that there was the - Chuck was dealin 1

t161Mr. Kendall, the Presidents ’ bwyer in this maP

with Kendall,

er. and Mr.

I 17 1 Bennett, the Paula Jones lawyer, and the [ 18 1 twere going to get

rl9ttoOQlim.

ether later in the morning. and we satdywe would get back

i2oj Q okay .

A He had some previousl scheduled press interviews.

i%;My recollection was those were sche4zuted for fairly early in

tz31the day, and I think we moved those back till later rn the

tzslday so that wed have time for Bennett and Kendall and Ruff ’

[zs]and company to get together and figure out how to react to

Page 87

[I 1 the story. Obviousty, the President was goin to be asked

tzlabout this and to give us time to kind of brief?irm.

t31 Q

r4lday.

You were gloomy. I think you said it was a gloomy

(51 A

161 0

It was definitely a gloomy day.

Were

A

tiiit was a shocki

I was eeling 1 - you know, it was - I think that

ou feelrng gloomy?

Q r%slto% describe the Presidents demeanor in that ’

: :,1‘ meeting you had w&r him that morning?

‘11, - - A

'121 Q

Intense.

Okay. How do you mean?

He was forceful when he spoke to us. spoke to

When he made the denial?

YeS.

Okay. Did he appear to be affected by the story?

Y_eah. ._ _

Bothered II

(201 A

Q

Oh. Id say ’ x

the story?

e was bothered by the story.

I dont know how soon this came out. I should ’

I::; know and Ive just forgotten. I don ’ t know if this was in ’

[23 1 the ori inal Post story, but fairly early on there were - I

t24jmight&ejumpmg ahead a little here. Fairl

[ 2 5 Iwere reports of several visits to the White !i

early on there

ouse by Ms.

OIC-Starr

Page 88

[ 11 Lewinsky and of several courier messages sent. Ill’ focus on

(2 1 the visits.

Did the President ever speak to that issue with

I : 1 you, the issue of If he didnt have an improper ’ relationshi

15 1 with Ms. Lewinsk

[ 6 ] ever speak to thaY?

what was she doing there so often? hid he

A He said to me - I dont think it was in this ’

Ii ; conversation I think it was a couple weeks later. He said [ 9 1 to me that aher she left. that when she had come by she

11 o 1 came b

[ 111 either By

to see Betty, and that he - when she was there,

etty was with them - either that she was with Be

[ I 2 1 when he saw her or that he saw her in the Oval Office wrt?

I I 3 1 the door open and Betty was around - and Betty was out at

t14lherdesk.

1151

1161 2 sook$!~t they werent alone in ’ - you know, in that

I 17 1 sense, that the door was open -

riai Q Okay .

I191 A outside the door.

Q

- and somebody was standin

I apologize that Im jumping a ’ 3,ead a liile bit.

i:yibecause we were at the Zlst, and now youre saying this ’

t22lwas -

(231 : A I think that might have been maybe like the 23rd.

I241 Q Okay. Is thete efrotberexptenetien-by-the

t2s1President in your presence between this denial to Mr. Bowles

Page 89

[ 1: on the 21 st and this conversation perhaps on the 23rd that

12 1 youre telling us about? ’

131 A

[ 4 1 question.

Is - Im sorry, but you have to repeat that ’

Q Sure. Is there another conversation - youve’

~~~mentioned the denial in front of vourself and Ms. Matthews

t

I

i 7 j and Mr. Bow&.

[ai A Right.

Q And now youve mentioned this other conversation a ’

fo~couple ’ of days later about sayin

i!!

that when she - she would

111 come by to visit Betty after she ft the White Ho$s$pnd

lzlshe would either be visitingBettymr+heWkd

t 3 1 the door - it would be in the Oval Office with the door141 A

Q

Wfih Betty there or the door would be open.

151

ld]door -

Okay. And presumably with Betty right outside the

171 ;I181 wasnt inside; is that correct? ’

1191

t

Thats correct. ’

Any conversations between those two where he gives

I::; any kind of - repeats his denial to you in your presence or

t22jgives an e~plana3a~n at all in your presence?

1231

1241 Q All right. Tell us about that.

[251 A We had a couple conversations in which he cieared a

Page SO

t 11 statement for McCurry - that he just cleared it, that had

;; ; been prepared b the lawyers.

Q day

A He sakl that the la ers si ned off on this, and I

~:~double-checked and said yes, and e w% .gsai “Fine. ”

t61 Q

A

Okay. These were public statements.

I71 Publrc statements -

[ai

[91

AQ Okay .

Q

- that said no improper relationship.

1101 Oka

A

Other than - Im sorry, go ahead. ’

And hen we repped him for the press interviews, r

i :: i which he did do on that W&esday.

I131 Q Pm-set .inte@ews.

Cl41

[ISI

6 pdayt intetvtews.

A And hen he met with Mr. Arafat the next day, and Y

i :76iwe had an$her;;ssion. kind of getting ready for the press.

[Ial

Cl91 A On a I those occasions Mr. Y Ruff was there. kind of

tzojled the prep and said, basicall [ 211 you know, theyve made two a ’ legatcons. that you ve had a

7, “You shouldn t go beyond -

[ 22 1 sexual relatronshrp, and that

i 23 ] to not tell- the truth, and you sK

ou ve. you know, told people

ould deny those.” You know,

(24jthe President was denying those things, but, “You shouldnt’

t251go beyond that.”

Page a5 to Page 90
3311

BSA John Podesta, 6/16/98 xMAx(1ul4

Page 91

[:I Q Did he indicate he wanted to go beyond that?

1” A I think he was getting that advrce from his [ 3 f counsel, and he was taking the advrce.

Q Oka

ii jOkay. Its’ a 13-paliy

Other than - can I ask this question?

question. Just kidding.

[A! Other than the statements that are being worked on [ 7 : that are for public consumption -

13:

[j‘ “a Righ - You will say this .’ ” -

13:

1::

i?::

“a Right. and, The lawyers have cleared this ‘ ” -

; Right.

any other statements by the President to you or i ::in‘ your presence where he is speaking substantively about the

t15jaltegations?

[16!

r17.Bowles -

I mean, youve mentioned the denial to Enkine ’

iisi Aa Yeah, right.

- and you had mentioned what he said to ou about

[:i:Monica coming by after she was transferred out. apparen

: on

rzl:the 23rd. $

izzi

tz3;by him?

Between those two times, any substantive statement

1241 A

t2s;Friday.

I had one conversation with him on the morning of

Page 92

I’ :

[I;

Q The 23rd in the morning.

A The 23rd right.

131 Q Tell us about that.

[4! . A See, we were getting read to do the State of the

and he was working on the S ate of the Union

iij %r$ft%% his study.

r

[ 5; this is

I went back there just to kind of get him going -

first thing in the momrng - and he said - you

[ 5: know, we sort of get en

[IT : and he said he was wo8.

aged. I asked him how he was doing,

rng on this draft. and he said to me

(1:: that he had never had sex with her, and that - and that he [ 12 : never asked - you know, he repeated the denial but he was

[ 13; extremely explicit in sayrng he never had sex with her.

I141

Cl51 4 .FrZvvZaVZFan’

Q

~:~~specific than sex, than the word “&?x.~

Okay. Not explicit in the sense that he got more

[I81 A

1191 Q

Yes, he was more specific than that.

A

Okay. Share that with us.

I:!isome spate of

Well I think he said - he said that - there was

rzzrsaid that he ha*41r

ouknow ’ what sex acts were counted, and he

never had sex with her in anv wav

i2jjwttatsoeveri24j

(251

Q Okay .

A -that they had not had oral sex.

Page 93

t11 Q Oka . You had started to talk about the - I

[21 MR. WISENBERG: The

r3jask a couple more? Hearing no out8

want me to show up now2 Can’ I

reaks, Ill’ continue for a

(4 1 while.

I51 BY MR. WISENBERG: I Q

if I think was on the 23rd also where he mentioned the

You had mentioned this other conversation that you i

[B 1 circumstances of Ms. Lewihsky coming by -

t91

Aa Right.

I:!idifferent conversation?

after she was transferred. Okay. Thats a ’ I

I121 A I think thats later in the day. ’

I131 Q

(14 1 in

Okay. Lets go ’ back to the first one. No question

f

our mind hes denying any kind of sex in any ’ way, shape,

1

f151or orm, correct?

1161 A Thats correct. ’

I171 Q All right. What else did he say at that particular /

I i 3 1 session?

1191 A He said to me, “I dont know how I could put that, ’

[z o 1 but thaYs the truth.”

Q Okay. Now, what about this meetin that

i::lis later in that da

ou think ~

Y.. 9

? Have you R saitI

tz3laboutthatit thGeg;rnt rn time,

iven us everythin

he Betty Cur-tie s uff?

p

1241

I251 Cl Okay. And was that speaking specifically to this !

Page 94

[ 11 issue of how many times - I mean, what context did it come

t2linto?

t3; A I think it was - the context was that was where

ELtnterchanaes are Penerallv between the

iz3jlawyen. and I encoura ed that. - - _

Q

I::ithe23rd. when you were in t e study with him?

Right. &ere pakmewithbintonthatmoming,

Page 95

[11 A

Q

Yes, it was he and I.iust he and I.

Did he mention anyt ing to you the Plst, 22nd. or

I: ;the 231-d about hi being involved in kind of ministering to

14 ]Ms. Lew\nsky? She was a troubled [ 5 lministerin to her or counseling heR”

non, and he was

‘A No.

.

I61

171 Q Did he ever say anything like that to you?

I201

(211

1221

1231

I241

1251

That% next week, right?

A Yeah.

Q

$

Okq When do you actually leave?

l$i&~~day. around noon.

A R’ ht.

0 day. 111’ be contact with your attorney about

Page 96

[ 11 scheduling.

121 A Oka.

MS. WtS&NBERG: Do we want to ask the witness to

ii :step outside for a couple of minutes before we excuse him for

isjtheday? ’

t61 THE WITNESS:

MR. WISENBERG:

I think theyre ready to go. ’

Why dont we ’ -Ill’ tell you what.

1; iI probably wont ask you to come ’ back in but Ill’ ask you [ 9 1 not to leave the area where your attorney k.

Cl01 THE WITNESS Oka

[::iexcused?

MR. WISENBERG: A% right. May the witness be

[I31 THE FOREPERSON:

1191

I201

[211

(221

t231

~241

t251

pa$e 91 to Page 96 OlC-Star+
3312
3313

In Rc: GJ Proudines MUll

““IZLD szwes DISTRICT ctnmt

FOR IHE DISTRICT OF CCN.VUBIA

In lx:

-D J"RY PROCEEDINGS

_-____---__------x

Grand .lury llwr "0. 3

Vn1t.d St.t.9 DisUlct Cwrt

tot the DisUlCt of Colubil

3rd L c0nstltut10n. ".Y.

Nashlnqton, D.C. 20001

Tuesday, June 23, 1999

The testimony ot JOHN DAVID PDDSSTA “.s taken in

the ~rr,m~ce et . full qu~uonm ot Grand Jury 97-2, lmpamlrd

0n aptat-19, 1991, coswncing l t lo:45 a.~.. betore:

SoILnoN YIsEnnEnc

. . .

Deputy Indrpendent couns*1

orrim 0r xnd0pendcnr COUMC~

1001 P,Msylvani~ iGnu*, Worth"*‘t

Suite 490 North

Yashirqton, D.C. 20004

e.g. ;

CONTENT S

YITNEss: Pap*

John David Podwta 3

GMND JURY EXHIBITS:

"0. JDP-2 mp or W-SC wing 0r white BOUSC

with aouclonr 64

Tuesday. June 23.1998

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Page3

PROCEEDING S

Wherfxpon,

JOHN DAVID EODESTA ’

was called as a witness and, after having been duly sworn by

the Deputy Foreperson of the Grand Jury, was examined and

testified as follows:

EXAh4lNATION

BY MR. WISENBERG:

Q Would you state your name for the record, please

A John David Podesta.

Q ArcyoutbesmeJohn~vi~Po&stawho~cd

&-rontofuslastweek?

A Yes.

Q AndthisisyourthirdA_ Was that a trick question?

Q No. Not at all. You’re not a John Podesta

impersonator or anything like that.

iie saw The ‘ X-Files” over the weekend I don’t

Imow.

Q And this is your third appearance in front of the

grand jury. Is that correct?

A Yes. The third before this grand jury.

Q Each time you have come, weve gone ’ ovex some of

your rights and responsibilities as a grand jury witness.

Do you need to have those reviewed for you?

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page A

A No.

Q All right. And you are here again with your

attorneyhfr. Kadzik?

AKhik.

Q Is that D pronounced?

. A K-a-d-z-i-k. Yes. Kadzik.

Q Kadzik. $kay. Before we go - we were on our

cbronologicaltrailwhichwilIendatsomepoint,w+xenot

goingtodoevery&yframJanuaryupuntiltheprescnfbut

Iwanttogobaclcforalittlebitandaskyou,didyouevez

giveacopyoftheDmdgeReportto--anyoftheaeDmdge

Reportsthatwerecomingoutbetweenthe18th,Ithinkthe

early morning of the 18th and the Post article, did you

yourself give any of those reports to anybody?

A Not that I recall.

Q Did you tell anybody, other than the people you’v

testified about, tell anybody about the Drudge Rep&?

A No, I think that there were at least a few people

intheWhitcHouseknewaboutitand,asIsaid,Ithink~

anticipated in our normal fashion that we get toge&r evuy

morning in my office just to think about what questions migb

get shouted at the President, and so that came up prior tr

the Post story because it was on the Drudge Report.

Q Did you - you mentioned a meeting, a normal, daily

meetine involvintz vow-self. Mr. Bowles and Ms. Matthews.
3314

In Re: GJ Proceedings Mull PagP Tuesday, June 23,1!88

Page !

1 A Correct.

2 Q And you mentioned that it was on the Zlst, the day

3 of the Washington Post article, and this was tbe President’s

4 fvst denial that you heard personally of the story. Is that

5 correct?

6 A That’s correct_

7 Q Do you red whether or not in that conversation

8 or in any other conversation hfr. Bowles urged the President

9 to get the story out as quickly as possible?

0 A I don’t specifically recall that he did that,

1 especidlly in that conversation which I think was -- my

2 recollectionofthec.onversationwasitwaslcMofaone-way

3 conversation in that the President was aware of the Post

4 storyand,again,Ihaveakiadof--itwas~~inthat

s he said to Mr. Bow&, and I kind of distinctly remember tllat

6 beaddressedittol%kine,thathedidn’tdothethingstbat

? were alleged in the newspaper.

8 Ithinkthat-mymcolkztiouisthewaywe

9 finishedupouthatwasjusttbatthelawjurswacgoingto

!o meet,&eywouldbebaektobirnantbatweuee&dtodothe

!l press interviews, but I don’t have a specific recollection of

I2 him saying that in that 4mwefsation.

13 Q How about in any other conversations? Or saying

!4 something to that effect?

!5 A Idon’t remember him saying that to the President

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1 Q Doyou remember him saying it to anybody else? 1

2 A No. I think Mr. Elowles fairly quickly put -- kind 2

3 ofdivi&dthereqonsibilityforworklngonthlsmatterand 3

4 focused tbe work of the counseI’s oftice as bandhng it. And 4

5 soifhehadaviewabouthowtohandleifIdon’tremanber 5

6 it other than to essentialIy hand it off to Mr. Ruff, the 6

7 WhiteHousecounstltodealwithitandthefcwpeoplewho I

8 &ah with the kind of public affairs, dte press reaction 8

9 si&ofit,whowoulddeatwithMr.Ruffandtharbemostly 9

0 got out of it. 0

1 So, again, if he had a strong view about it, I just I

2 don’t recall it, but within a day or two he wasn’t really 2

3 participating in any discussions about how to deal with the 3

4 press on it and certainly not in any, I don’t think -- I’m 4

5 not aware that be was dealing with any discussions with the 5

6 lawyersaboutwhattheywendoin&abouthowrohandiethc 6

7 matter. 7

8 Q Did the President directly or indirectly in the 8

9 fmt few days after the scandal broke, did he ask you 9

10 directly or indirectly to reach out to anybody or to ask 0

!i otbezn to reach out to auybody, to a particular pemcm, for 1

:2 any reason? 2

:3 A I think we were mOStiy talking t0 him, so if YOUR’ 3

:4 searching for something you’ve got to prompt me a little 4

15 bit. I don’t remember him giving any specific direction to 5

Page7

talk to people.

Q As an example, we need to get a hold of so and so

on this. Betty Currie, Vernon Jordan, just as exmp](

A No. NO. Witnesses? NO, I don’t recallhimdoinl

that at all. Not with us.

Q What about anybody eise?

A I didn’t participate in the meetings with the

lawyers, so 1 don’t know whether --

Q You never participated in any of the lawyer

meetings?

A we&Ithinktherewen!~awyerS--thenWere

somdmes Iawyers in meetings that were brieting the

President about how to ma& including starting vimrally

thatday,onhowtoreacttothepmss.

So the lawyers came to those meetings, which I

would call, I guess, press meetings or communications

mortiqs. ButthePresidentwasmeetingsepara&lywitbhis

lawyers and I did not participate in those meetings.

Q Okay. Didanybody --

A Did I draw that distinction sensibly7

Q Itm&stood.

A Okay.

Q And I’m kind of a touchstone, kind of the lowest

eommondenominator. IfIcanunderstandit,auybodycan

handle it.

A Okay.

Page z

Q What about somebody ek? Anybody ek ask you

to-inthef~fewdaysorweeksoftbeseandal-reach

outatxlgetaholdofmmebodywhoeouldbe&met&ed~

a potential witness?

A No. NotthatImcall. Imean,Ithinkweagain,Idon’treullbeingdimetedtodothis,butweyou know, obviously, we’re taIking to the press. There

were-peoplewereconcemedandcallingus.

IhadameetingwithMr.RowlesonthcHiIlwith

theSenateDemoc&cGurcusbutIdon’tremember-you

know, I’m just basically saying that the President had denied

thesechargesandtbatweweregoingtomoveonandtryte

accomplish ti goals that he set forth in the State of the

U&m, but bqmid that, I don’t -kTlIC&Odydinc(iagmC

to talk to a witness in any regard.

Q Okay. And you didn’t do that on your own, did you?

A No.

Q AndwhenIsaydimt,noone.askedyouasopposed

to direct& which implies ordering.

A No. No.

Q No one requested either. Is that correct?

A Totalktoawitness? No. I don’trecalfthatat

all.

Q Or somebody who could potentially be a witness.

Diversified Reporting Services. Inc. (202) 296-292~_^ Page5-Page8
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:nRe:GJ Proceedings Mull

pages

I A I mean, given this investigation, I think anybody

z in the White House is potentiaIIy a witness, but I’m not

3 focusing on anything. I can’t remember anything that would

4 kind of draw a bead on your question.

5 Q Okay. And you did talk to immbers of the press

6 from the get-go, I take it, both on and off the record?

7 A 1 talked but not routinely to members of the press,

8 but I talked a little bit to members of the press.

9 Q Would that be primarily off the record or

IO exclusively off the record?

I1 A No,ItaIkedonthemcordandImayhavetalked

t2 off th record The press lives in three worlds. Thzm’s

13 san&ing4kdbcLgrwndwhichusuaRymcaosaWhitcHousc

14 official.

15 Q Okay. What are the other two worlds?

16 A Offthenxord,whichmeansthattheycan’tquote

t? yo~anbackgrwadwhichmanstheyquoteyoubutnotby

I8 namc;andonthencord,whi& nxans you’re quoted by m

19 Q Okay; And that happens aII the time, nothing

20 inherentIy -- correct? That you talk to the press?

21 A Right.

22 Q ~to~at~~~H~~~~p~.

2 3 A Right. But it was certainly not my primary

24 mponsibility. Thertareottnxpca~b?taIkir@tothepnxs,

25 priocipally Mr. Kmnoziy, from tht White House. Mr. MeCurry

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Q Okay. Butwashekindofthperson&signatedto

be thz main interface with the pmss?

A Yes. Otkr than McCurrys’ regular on-the-record

bridings.

Q Plus there‘s a guy named Lockhart, too, coirect?

A JoeLockhartisthedeputypressseuenuywho

works for Mr. McCurry in the press mcmtary’s office and he

would on occasion talk to the press as well. He often

travels. Also, he often travels with the Pm&lent.

Q Lockhart does?

A Lockhart does. So if they’re travehng, fairly

aftezi cm domestic tips - or I’d say most often, Mr. McCurry

doesn’t travel QLY: of the deputy press seuetak traveb,

that’s usually Mr. b&hart, so he’d be intcrf~ng with the

President in that regard.

Q AndMr.Kennedyhasbeenthueframtheget-goof

this particular scandal?

A ICan’t remember precisely when he started, but it

was right about the time that this brake into the public. We

had a person whc h.s become. tind of w&l known in Washington

namd Lanny Davis who I think OvcrlapJJal for 8 wek or two.

Pagem Tuesday,June23,1998

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Page 11

Lnny had worked, again, in the counsel’s office as the press

spolresman for the counsel the previous year on the

congressional hearings on the campaign finance issue.

Q So Kennedy has thz Lanny Davis slot?

A Yes. Yes.

Q Da you know through hearsay or otherwise if anyelszwasaskedtozxacb~utinthefvstfewweeks?In&

wor~togetapotentialwitness,wcoeedtolalkto~to

this person. Do you have any knowledge of that?

A No.

Q Is it safe to say there’s a flurry of activity

g~~~~~~~~~~~? AndvT&n:

say scandal hits, let’s talk about the 21st, because from

whatIgather--youcorrectmifI’mmoo&fnnnwhatI

gather from your testimony last time -

Pardon me. Them’s a knock at the door.

@merruption to the prcceedings.)

MR. WISENBERG: Let the record reflect that I wen

tothecloorandIopmedthedoorandIreceivedapackage

and I closed the door.

THE WITHESS: It’s not donuts.

(Laughter.)

BY MR. WISEHHERG:

Q Itakeitthatthemwasgrowingconcembetween

the -- I guess starting the Friday before the deposition,

Page 1:

1 ~t~~~~o~~~~~~~~z~

2 themwasgrowingconcemwithintheWbiteHouse. Isthat

3 uxzct? Aboutthisstory?

I A Well, I would break that into different ekments.

5 Therewas,asIsaidinmyt&i.mmy,onFri~,wewem

6 bzsingfrwtTii~wbichatlhattimcPormdcdtilaa

7 dif-fenznt story about Mr. Starr and his invesngatiim. Then

B Saturday was the deposition. Mr. I&off raised a

9 conversation with me.

3 By Saturday night or early Sunday morning, the

I DNdgeReportwa!sout. Ithinktithatpoinfthxewas

z concern, but I think it was at a relatively low level that

3 Mr.Bennettneededtohandlethis.

6 And then by late Tuesday, when the Post called and

5 said that they had details, introduced Mr. Jordan, as I

5 meaIl, into the story. I don’t think I knew about that

7 before. AndsaidthatMr.Statxwasinvest@@it. Ibm

3 Ithinkwewereatahighlevelofconcem.

2 Q Okay. And when you said earIier --

1 A And then, obviously, when the paper came out, WI

I ~--y~~ow,Iwould~y~t~~ag~~of

2 conoem.

! Q All right. And it becomes a big issue within the

t White House starting on the 21st.

5 A Yes. Maybe the night of the 20th.

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n Re: GJ Prwedings M&i-PligP Tuesday, June 23,199s

Page 13 Page I!

1 Q Okay. I used the term flurry of activity. That’s 1 unusual, but you would not normally expect to see on a

2 not exactly a term of art, but its fair to say that ’ there 2 day-to-day basis at the White House that you saw on the 19th

3 are a number of people who start getting devoted to this 3 A I don’t believe so. 1 mean, 1 said that I had a

4 issue in its various aspects. Is that eorreet? 4 meeting with John Sweeney, the head of the AR;CIO. and his

5 A Yes. 5 number two guy over there, his executive assistant The

6 Q I want to go back for a minute to the deposition, 6 numba tie guy is Tmmpko. but a guymJury Shsy. You

7 the day of the deposition, the Saturday of the deposition, 7 know,itwasunusualthattheywnein,hutwcwcrekiDdofa

8 January 15th. You said that you wap: at the White House 8 sktdetd Crew that day.

9 preparing forth state of the union address. Is that 9 Ihe Aresjdent went out to, I think, Cardozo Higb

0 correct? I o School and painted the school, doing service on that day

1 A That’s correct 1 I AndItbinkbewentwitbTburgcodMar&all,wboistbt

.2 Q WboelsedoyoureeallbeiiattbeWbiteHouse 1 2 cabinetseu&ry,andmaybcsyIviaMathw%wl3oistbz

3 that day that you saw? 1 3 other Deputy Chief of Staff, but 1 don’t remember anybody

.4 A Well, I mez&ioned my conversation with I%% Milk if 4 unusual around the white House that day.

.5 andhfr.sos& Wchadawboltccamin. Iwouklsaymwtof 1 5 Q myoud-

.6 th:scniorstaffof~didpoysubstantiveworkonth:statc 1 6 A IdOn’t remember seeing, for example, Mr. Bennet

.7 oftbcunion,soitwouldhave~~numberofspeech 1 7 oranyonclikethat

8 writers led by Mr. Waldman, who is our chief speech writer. 1 8 Q All right How about h-ir. Jordan?

9 ~LyJ~T~~~~of~~~~ 1 9 A l~‘t~~.Jo~~~~~M~.

a writers, I think was tbere,~wbo had a principal role in tbt 20 Q Okay. when doyoureeallseeingbim?

!I state of tile union. 2 1 A ltbinklsawbimtbereonTuesday.

!2 lthinkMr.Bl~thalwasthcre. AnnIewis,who’s 22 Q AlI right. Tell us wbat you ncafl about that?

13 communications director. I think Gme Sperhng, who is the 23 A I remember just literally bumping into him in the

14 Lad of tbz National Ekonomic Council; Bxuce Reed who is tbz 24 hallway. I don’t know, it could have been Monday, but my

I5 head of the Domestic Policy Council; Elena Kagan, who is ther25 recollection was that it was Tuesday.

Page 14

1 deputy dilwtoI of the Domestic Policy Council.

2 Someone, I’m sure, was them from the environmental

3 CEQ, probably Katie McGinty, but I m’t placethat for

4 certain. lbeVieePr&dent’sstaffwastlmre,Ithi&as

5 I recall.h4r. Begalq who is a emnmunieations person,

6 counsellortothePresi&nt. Mr.Emanuelwasthmewhois

7 tbesame-Iguesstbesarnejobdeseription.

8 Sowebadalmost-Idon’ttbinkMr~Bowleswas

9 them,butlthinkwehadalmostourwholeseniorstaffthe.m

0 working on the state of the union.

1 Q Anybody tmusual the% who you wouldn’t norm&y

2 expecttobethere?

3 A th that day?

4 Q Right.

5 A Not tbat I recall.

6 Q Did you interface at all on that day with

7 Mr. Blumenthal about the calls you’ve testified about

8 previously that were starting to come in?

9 A I don’t think so.

10 Q How&&on--1thinkyousaidyouwemnotthem

:I at all on Sunday, correct?

!2 A Right.

13 Q How about on Dr. King’s birthday? Did you -- any

!4 people then: -- that’s the 19t.b any people there that were

:5 unusual? You would not normally - and I’m not saying supa

Page 1,

Q what do you remember about that?

A I just said hello to him. I just said, you know,

like “How’s it going?” And be said, “Fine. Things are

fine.” That was it

Q Okay.

A Hewasintheballwaybetweenmyoffieeand

Mr. Enlanuel’s offee. I think be was coming out of

Mr. Emanuel’s Office

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Q How well do you know Vernon Jordan?

A I ]mow him professionally, I’d say, pretty well.

Imwe’m friendly. We’re not - I’ve nevcz hun to his

hous:todinnerorhe’sneverbeentomyhousefor~. I

don’t think I’ve ever had lunch with him. But I’d say we’re

friendly acquaintances in a work envinmment

Q Has be ever come specifically to visit you about

anything at the White House?

A Theonlytbinglrecalltbatbe-andIwouldsay

that he popped in on me would have heen months hefore that

He’s a fairly close friend of Mr. Bowles and them was a time

in the - Id ’ say spring of ‘97 when Mr. Bowles was sort of

rcgrettiogbayingcomebacktotheWhitcHousc,ase&immt

I’msuresharedbymanyofthepeopleattbeWhittHo~

But at that point, Mr. Bowbzs had -the President

hadkindof~Mr.BowlsintocomingbacktothcWhitc

House in Novemba of ‘96, he came hack as Chief of Staff

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Page I7

By the spring of ‘97, he -- you know, he had kind

of left his family in North Carolina, I think he was

somewhat, you know, as I say, qretful of having come back.

And Vernon was a good friend. I think they’re pretty go&

fria&. AndInxnanbcrhimpoppingiaoamcandaskiqmc

how is he doing, was be okay, he seemed sort of down about

the work and the job and being there.

He was a witms in the Whitewater matter, not this

matter,buttheWbitewatermatter. Itbinkthatwassortof

bothering him.

Q Bowles? Bowkzs was?

A Yes. And I think that’s the only occasion I

fununlJelw&reve7nimachUluycanXtoseeme. IKcaUbe

kindofpoppedinonmeinthatregard. Andtbenhewould

5 callmeoaQina~eandsayhowisErskiacdoingaadI’d

6 say he’s fine or whatever.

7 Q Did you ever have a conversation with him or -

8 well, let me start it this way. Did you ever have a

9 conversation-with Mr. Jordan that was in any way, shape or

0 form about either the Paula Jones matter or the Monica

:J Lewinsky matter?

3 A No.

,3 Q Were you ever a participant in any way or an

4 observer of a conversation he bad with anybody elsz about

5 those two matters?

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A No. I don’t think so.

Page 18

Q I take it, then, that since the bide&s

deposition you’ve had no convefiations with Mr. Jordan.

A Itautedtohimoncebyphoae,samefllbjoctasmy

previously phone conversation that I’ve described. He

actually, I think, had called for Erskine in the office and

F,rsk&wasn’ttbere,h4r.Bowlcs,andItbinkIwasjustkind ~

ofwalkingbyandIpickedupthepixmeandhejustwas

calling to see how he was doing.

Q Who -- again, I am excluding what you’ve read or

~inthepressorheard,doyouimowofanyoneelsewho

hasbeentall>oMr. JordanonbehalfoftheWhiteHouse

or who works at the White House since ttw: President’s

dcpositioc~ about tbc Monica L&n&y issue? And I doo’t mean

nozcssarily you personally know, but do you know or J.aave you

heard, again, excluding the press.

A The only occasion that I re&.I knowing that is on

Thursday, the story came out on Wednesday, the 21% on

Thursday in one of our press pq sessions, Mr. M&my asked

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Pagem Tuesday, June 23,199s

Page 19

J from the people dealing on the press side of this. we wgen’t

2 trying to get a lot of information. We wanted to give that

3 the lawyers. And I think Mr. McCurry said, “Well, you ought

4 to tell Chuck about that and fii out what you want to say

5 about it”

6 Q All right. There was no more elaboration on the

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conversation betwezn’the President and h%r. Jordan.

A Not that I recall. I think it was very brief, but

I member it.

Q Okay. Now, is that it? With respect to my

questionaboutanyooeinthcWhiteHouseoranbehalfofthe

White House talking to Mr. Jordan since the P&dent’s

deposition that you -

A About this matter?

Q About the Monica Lewinsky matter.

A I don’t know of any other people who I’ve talked to

about that

Q How many conversations have you had with Betty,

Cunie since tbz story broke 011 tbc 2 1 st in any way, &ape or

form about Monica J.zwinsky oc tbc Monica Lcwinsky matter?

A Ithinktheanswertothatisnane,althoughIhave

asked her how she’s doing. Especially after her first

appearance, I was concerned about her.

Q JustbecauseoftheA It was like an “Arc you okay” conversation. -I

Page 21

Q And what did she say to you?

A I think especially after her fifit testimony I

thinkshewasprettyshakenup.

Q Do you recall what she said?

A Itriedtocomfortheralittlebit. Is&-&you

know-justthingswillbeokay.

Q Did she say anything to you?

A No.

Q You said she was shaken up.

A Well, I think SIX? looked and seemed shaken up.

Q How about Nancy Hrm&h? How many c~va~ations

have you bad with Nancy Hanreich ~JIC story broke. on the 2lst

in any way, shape OT form about Monica Lcwinsky or tbc Monica

Lewinsky matter?

A Again, I would say none other than one of thz day

IcamehereshewasouttheE. 1sai~“Arey0udone?” she

said, “Yes, I think so.” And - I mean, so it’s kind of

passing, “Are you going to the grand jury today?” But I’ve

not had any substantive conversations with her aboui it.

Q Okay. Same question with respect to -- I’m going

to ask this question with respect to a few more people.

A Okay.

Q Evelyn Lieberman.

A I don’t believe I’ve talked to her at ali about

anything.

the President have you taJkcd to Vemon and the President 20

said, yes, he had. 21

Q Any conversations beyond that? I mean in that 22

particuhu exchange. Anything about Mr. Jordan or the 23

conversations. 24

A No. I think that at that point, again, I think 25

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1 Q Okay. Ever in your whole life or just since the

2 21st?

3 A No, since the 21st. I may have, but I don’t recall

4 speciticaliy. Well, obviously we worked together previously.

5 Q Okay. How about -- refresh my recollection,

6 please, on how you worked together previously.

7 A she was the deputy press secretary wkn 1 was tix

8 stdfxcretary. Andshebeforethatwasthechicfofstaff

9 totbe--sbewasliketbecbiefofstafftothe&iefof

IO Staff of the First Lady when we first were tire.

II Q Okay. All right Now, she was deputy--

12 A AndIworkedwithherwhensheworkcdontbcSenate

13 Judiciary Committee. I’ve known her for a long time.

14 Q And ti deputy -when she was deputy chief of

I5 staffto--

16 A oh, deputy Chief of Staff --

17 Q whensbewas--

I8 A Rigbt.

19 Q -- to Mr. Panetta --

10 ARight”

II Q Were you working in the White House then?

!2 A No. ThatwasafterIleft.

13 Q So as far as you know, you’ve had no convemation

14 witb her relating to the Monica Lewinsky matter.

!5 A Correct I’m certain of that. And again, I don’t

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Page 22

recaIIeventalkingtohersiocetben.

Q How about ErskineEiowles? You mentioned same of

~~n~~~you~dl~~~~~1~~

initial conversation. And I thiuk you indicated, you correct

me if I’m wrong, that you said we probably shouldn’t b

talkingabouttheaubstanceofkindofthchistoryofwhat

you and be bad done.

A That’scorrect,

Q And did you maintain that, you didn’t talk about

that with him?

A I have not taIked about mat with him.

Q AlIright. I take it you’ve talked about

tin- you’ve talked about the Lewinsky matter with him

incatainotherrespectsjusthavingtbdowithhowitneeds

to be handled as an issue?

A very lit&.

Q Okay.

A Helms--Itbinktbatbehaslaiddowntbelaw,if

you will, to the substantive staff that they should tend to

what they’re working in the White House for. which is to try

to get some progress on the domestic policy or national

security front, and I think to some extent by example and to

some extent just by preference, he has led tltat effort and

virtually spends zero time on this.

Q Okay. Do you recall any discussions with him other

story in the newSpaper or -- but not the substance of it.

He really kind of basically doesn’t get into it at

all and so he -- you know, it may be -- you know, kind of

whem is this going or when is it going to end but literally

conversations that last for seconds, not minutes.

He has just not gotten into any part of -- I don’t

know whether he’s independently talked to Mr. Ruff, but not

to my knowledge.

Q Have you ever talked with him about what you all

would do, what you would do or be would do if the Pnnidan’s

denials to you turned out not to be true?

A No.

Q Would it be fair to say that the President’s denial

to you, to Mr. Bowles on that fvst day, I think what you’ve

character&d as a stmng denial, plus you’ve mentioned two

later statements the President made to you -

ACOlE&_

Q Would it be fair to say those had a strong effect

on you?

A Yes.

Q And why is that?

A I didn’t think he was equivocating at all. He wp

I Page 23

I than what you’ve told us about about the Lewinsky matter?

2 A I think RIaybe, YOU know, jUSt like literally

3 passing rtfereaces to, you how -- you know, there’s an up

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1 m-y force&I. I believed what he was saying

2 Q 1 want to talk about the twice daily meetings that

: 3 discuss, among other things or perhaps exchtsively, the

4 LewinSky matter. An you ever a participant in tho3e

: :5 meetings?

/6 A Yes.

7 Q lheyareat~ugblywhenandwhenduringtheday?

B A wea, you sort of impliedB which isn’t

49 lnle.

II3 Q Okay.

1 1 A Which is that t&y involve exclusively the Lewin&y

1:2 matter.

1:3 Q Okay.

11 0 A We had - previously, the wbole previous year,

1:5 Wehadmetonthecamp~finanQissueandthatmeeting

115 occurmd essentially after - we have the senior staff

1’7 mezting and then we have a communications me&ing, a big

11B communications meeting, to try to plan out the day,

I! 3 andthenwewouldmeetonwbatmigbtbeputintbe

2fI scandaUcongressiona.l investigation pot A somewhat

2.1 different group of people.

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I After this story broke, we started having that

1 meeting in Mr. Ruff’s off&., but that covers anything that

I we were being attacked for. I’d say in the spring, a good

5 chunk of that was this investigation, but we still have Mr.

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Page 21 Page 27

Burton attacking us on campaign finance and we have other

umgressional investigations attacking us on various sundry

things that they’re poking at us on.

And now, in fact, we spend -- and to the extent

that I participate in the meeting in recent days we’ve spent

agooddeatofitonhowwe’rercspawflngtotheChinaissoc

with regard to missile technology, satellites being launched

on Chinese missiles.

Q Andthemeetingsarewhattimeofday?

A we meet at about 8:45 in the morning. That’s kind

ofbccadrawabacktoabwt8:3Osothat\recanbavetimeto

discuss this China stuff. And then 6:30 at night_

Q And what would you call these? So they’re not

exciusively devoted to the Lewinsky matter.

A Yes. Ahhough hre’s sort of a revolving cast of

characters which is that there are same people who come and

&al -- the people who deal with this investigation, campaign

finance, that’s kind of one group of people.

The people who deal with the China part, there’s

sort of an overlap, but some people leave and some new

paopk - UJC National Security Cotutcil pcopk cotw who don’t

CanetOthtQ Do you have a name for these meetings?

A No.

Q Okay. You are typically an attendee at these

I definition than three groups getting together, is it

2 basically -- primarily, how do we respond to the press?

3 A Yes. There is a -- you probably know this, but

4 there is a separate meeting of lawyers that precedes this

5 meeting, I think both in the morning and the afternoon,

6 although I must tell you I’ti not sure of that. I’m sure that

7 it happens in the morning, I think it happens in the

8 afternoon. In which just the lawyers meet_

9 Q And when you say the lawyers --

0 A The White House Counsel’s Office and I believe

1 ihey’re-attatonepoinfthey~tallringtothe

2 outside auomeys as well in that cxmvefsation. Mr. Kendall

3 with respect to your investigation. Mr. Bennett I think

4 might participate, I’m not sure.

5 Q Okay.

6 A So that’s a separate meeting which excludes the

7 uXnmunications pa& and cxclti mc. And 1 think tk focus

8 on thaf meeting is more this investigation or the Starr

9 at-large investigation. I don’t +ink they get into what

o Congressman Hoekstra is doing about the Teamsters or

I whatever.

2 Q But this is primarily -

3 A This is a press meeting.

4 Q What I’m going to cti the twice daily mfzetings.

5 A Rjpht

Page 26

1 meetings?

2 A I would say ti. answer to that-is no. I probably

3 gothreedaysamekinthmming. Wedothemeveq

4 moming,everyafterwon,andIprobably-soI’mthere

5 6Openrntofthetimeinthemomingand1probablyamthen:

6 maybe once a week in the afternoon. I’ve got more

7 nqonsibiity on China, so I’m a little bit thaz more often

8 inthelastcoupleofweeks.

9 Q You’vetoldusthegeneralthingsthatarr:the

D subject matters of this meeting.

1 A Right.

2 Q WhichItakeithavetodowithareasthatthe

3 administration feeis it’s being attacked on and what is

4 the--

5 A It’s kind of that cross between what the lawyers

6 are doing and what the press and the communications and to

7 some extent the Capitol Hill people are doing.

B Q Ail right. Is it an effort to brief various peopIe

9 about what the -- people who have different roles? You

D mentioned the legislative, legal and press people. For them

i tokindofgettogefbRandbriefeachotha,beonthesame

2 page? Is that a fair statement?

3 A Yes. That’s a fair statement.

4 Q Are they primarily -- you’ve told us the subject

s matter. so -- and mavlx YOU can’t give a more snecific

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Q IS a press meeting.

Page 28

A ~~/uxxKN&&O~~ meeting.

Q Atthatme&ng,attbzsetwiadailym&ngsor

at any other meetings that you’re aware of do the

non-lawyers - wel&letmestrikethatbecauseyou’rea

lawyer.

Doesan bodygetbtiefedonwhatwitnesseshave

said either to tgrand jury or to our investigators? I‘m

not implying that there’s anything wrong with that.

A I’m going to have olfe exception to this rtde, but I

would say that vimtally never.

Q Okay.

A The=% very little information exchanged about

what’s going on in terms of the conduct of the investigation.

It’saze&ingthat’sfocusedonwhatstoriesaxework&

wharreportasareasking,what’sgoingtobeoathemoing

news, what just was on the evening news, do we have to

respond to it

Q what’s the one exception?

A Relatively early, you can probably place thz date

for me, thae was one occasion which cmssed over on that

front which is that The Wall Street Journal had post& a

stMyonitswebsi~eOnMMastRChiefNelvishadsaid

in the grand jury, is my rec&zction, which we were told

was false and that his lawyer was codng it and I

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I Page 25 Page31

1 A Thats ’ cdx-rect You raised one issue with M the

2 IasttimeIwashere~chItalkedwithmylawyer~. 1

3 don’t know whether that question implies that --

4 Q Are you taIking about the meeting back in &

5 summerof ‘97?

6 A No.

7 Q Okay. What are you referring to?

8 A You asked me about Mr. Hilley the last time I wa

9 here.

10 Q Okay.

II A And I told you I had a conversation with my lawyer

I2 about Mr. Hilley.

13 Q Okay. Ctlurr than that incident and the Mills

14 incirknt or the - I’m sony, the Nelvis incident that might

IS have been Ms. Mills.

16 A It could have been Mr. Ruff or Ms. Mills, I’m noi

17 SUE which lawyu said it, but it was one of the lawyers. I

18 guess I feel that I cau be reasonably categorical that then

19 dontdhuswbatwitnescsaresayinginthegmndjury ’

20 with us.

21 Q okay.

22 A &I CoullselS‘ OffxX staff.

23 Q Are you aware that such debriefmg is going on by

24 somebody in the White House? And, again, Im’ not impiyiq

25 theres anything wrong with that. ’ Am you aware that it is

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believe -- then the story didn’t rue and it’s become a kind

of famous or infamous case of the press, so that the Wall

Street Journal ran it on their web site but never printed

it in the newspaper or they printed a different story in

the newspaper.

So that’s - I mean, I’ve kind of thought about

this a little bit and that’s the only occasion I can think

of where people said that was not what somebody testified

to.

Q Okay. And what was --

A hOWIxkMi.Ug.

Q And what was false, what you undemtood that WB:

false, was that Nelvis testified to X in front of the grand

jury.

A Right Imean,itwasavery--itwaskindofa

salacious story on the web site and the wzb site cited

Nelvis’ testimony as the basis for the story and I believe

thatthelawyerissuedsomestatuneutthatsaiditwasuot

correct.

Q Nelvis’ lawyer. That you were told --

A Thats’ correct

Q llratyouwaetoldatthismee&g,youandthe

other participants were told by somebody from counsel’s

office?

A Yes!.

Page 30

1 Q That the story was false and that his lawyer would

2 be correcting it.

3 A Had cormc@d it or issued a statement or was

4 issuing a statement, I don’t rememberthesequen%

5 Q I’m not trying to be too picky here, but the story

6 could bc false in two ways: number one, Nelvis didn’t

7 ~tothatinfrontofthegrandjury;numbertwo,the

Bthinghesupposedlytest5edtoneverhap~

9 A 1 think - my recollection is both things were

3 true. Both-Ithinkitstartedwhhthesecondand

I therefore at least implied the fust, a, that it didn’t

2 happen and therefore he didn’t testify to it

3 Q Okay.

4 A But, you know, I don’t have real recollection of

5 exactlywhatwassai&otherthanthestorywaswroo&bad,

6 and that they were trying to correct it and that he didn’t

7 aaythethingsthathadhappenedandthereforchecouldu’t

3 have testified to them.

> Q Who told you that at the meeting? Do you remembdl

1 A One of the counsel’s people, but I’m not positive.

I I think maybe Ms. Mills, but I’m not positive.

z Q other than that incident. either at these twice

3 daily mc&ngs or anywhere else, you have not received a

I briefing on what any witness told an OIC investigator or FBI

5 agent or the grand jury?

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Page 51

going on with at least some witnesses?

A I know that it’s common practice, but I dcn’t know

much beyond that I don’t know specific facts.

Q Okay. Amyouawarethatsonxhdyisdoiithat?

A I’vereadthatinthenewspaper,but,asIsaid,

Idon’t~~spacificfactsdsatIuur~lyou~lawyer

XtalkedtoIawyerYorta&edtowitnessZ

Q I~it’s~~~~sp~~dI~

Mr. McCurry has acknowledged that it goes on. I’m nd

positive. about that. But what I’m asking you is even if

you’re not told about X lawyer, are you awBn that there ate

somepeopleeitherattheWhite:Houseoractly:onbchalfof

theWhiteHouscothathmwhatyou’vcnsdinthepnssthat

one of their jobs is to debrief -

A IguessIassumeit,butIdon’tknowit.

Q Okay. To debrief witnesses. Just to finish the

question.

A Debrief witness -

Q WhohaveeithzrbeentothegrandjuryA That would be --

Q we& when I say witness, I’m including -

A IguessIdon’tevenassumethat Iassumetha! ’

some of the lawyersBle taking to some of the other lawyers,

but beyond that, I don’t -- I nxan, that’s kind of standard, I

1

common nractice. I

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1 Q And that would be an indirect way to find out what

2 a witness had told an investigator. Is that correct?

3 A I assume that the lawyers talk to lawyers which is

4 standard common practice but beyond that I don’t know

5 Q Okay. Well, what I was starting to say earlier wa

6 that my dcfmition of witness would include a witness who bad

7 ~inthegrandjuryor~hadtalkedtoanorc

8 investigator, so I just wanted to make sure what it is tha

9 you assume. You don’t know anythin& you haven’t been toll

1 0 anything other than what you’ve read in the press.

1 1 What is it that you assume goes on? That some

I2 lawyers in the White House talk to some layers for witnesses’

1 3 A Yes.

1 4 Q Okay: And would yeu also assume tbattbcywouldbc

1 5 talkingabcu~amongothertb@s,wbatthewitncsssaidor

1 6 was asked, either by an investigator or at the grand jury’

I 7 A I would be - I guess I would assume that, but I

1 8 don’t know that.

1 9 Q Okay, Do you know based on anything, includin@

2 0 what you’ve read in the press or what you’ve c&&cccl from

2 1 tbatwl&indi&lualsintheWbiteHousemigbtbereceiving

22 that information, directly or indirectly? That is to say

2 3 receiving information about.what witnesses have told the OIC

24 or the grand jury?

25 A Well, I would assume it would -- I’m like totally

I

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Page 34

speculating. Do you want me to go ahead and speculate?

Q Yes. Because you‘re in a better position to do

that than we are because you work in the White House.

A I will speculate and think that it would either be

Mr. Ruff, Ms. Mills, maybe Mr. Bnzue.r, who is the Associate

White House Counsel. Maybe Mr. Lindsey.

Q Okay. Do you knew wbctber or not that information

has been imparted to Mr. Kennedy?

A I don’t know.

Q Okay.

A Mr. Kennedy usually woti up some response, much 01

which is not about facts, but only that we’re not going tc

respond to the facts until the investigation is concluded or

something, but he clears that with Mr. Ruff before he says

anything.

Q Okay. Do you know whether or not he would be,

based upon your speculation, because I asked you whcthef or

not that would be shared with him, do you know whcthtx or not

that would be natural in the course of things the way the

counsel’s office works that hc would be one of the ones who

could be being debriefed about witness testimony?

A By outside lawyers or witnesses?

Q Yes. Directly or indirectly.

A I would think that would be unusual. 1 wouldn’t

think so. I don’t think they would.

.PageTM Tuesday, June 23,1998

Page 35

1 Q Okay. It would be more likely -- that scenario, it

2 would be more likely that you would hear it from a front tier

3 team such as Mills, Ruff, Breuer or somebody like that.

4 A Right

5 Q Do you know if Mr. Breucr ever talks to the press?

6 A- Well, I know he has on occasion in the campaign

7 finance matter. I don’iknow whether he’s talked about this

8 matter to the press.

9 Q On or off the record?

IO A Onorofftherecord

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Q Are there sub-meetings of these twice daily

meetiagstbatyoutverattendthatdeatwiththesamesubject

matter?

A &b-meetings?

Q Right You talked about in the past kind of

hallway conversation when you bump into somebody -

A Oh, if I think it’s something that’s hot, you know,

people might raise it.

Q But I meant something more formal, a smaller group

thanmeetsinthetwicedailymeetings.

A No. Not - no, not really. The only thing I could

remember that’s sort of like that is when Judge Johnson

unscaled tbc order in tbc executive privilege case, there was

sort of a slightly -- there was the lawyers plus a couple of

others, myself, I think there was like a pre-meeting with --

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Page 36

they knew I was a lawyer. I think for that purpose they

invited me in to see how we should respond to that.

Q Ail right. How you should respond to the

unsealing?

A Totheunsealkgandtknatk-Ithinkthenext

day we then discussed a little bit - they got our opinion, a

slightly larger group, Begala was there, myself. I don’t

tbinkMr.~&lwaathem,butIthink-JoeLockhartwas

there.

They got our view about -- they asked for our

advice about what, if anything, to appeal and whether it

mattered wbctker they appealed executive privilege versus

attorney-client privilege from a public relations and

press perspective. We gave our opinion. We then left

and they had a discussion about what legal advice they

wanted to give to the President and I didn’t participate

in that.

Q They being the lawyer only group.

A The lawyer Ody group. Right.

Q I think I’ve told you - certainly this was

implicit .in your instructions that witnesses - or the ones

that you got tile firs time you were belt? -- that witlEsses

in front of the grand jury are-not bound by secrecy.

Witnesses are free to tell anybody what happens in the grand

jury.

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Page 37I

Tuesday, June 23,1998 t

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I’m giving you this by way of a preface to my next

question because I’m going to use the word leak and I want t<

be clear that for my question, I’m not confining leak to

6(e) violation. Do you understand?

A Yes.

Page 39

1 A No. Do you know what the reporter was?

2 Q 1 can’t remember.

Q I’m referring to leak as just basically any non-on

the record discussion with the press. Is that clear?

A Yes. Well --

Q Any off-the-record or background discussion with

the press that involves the giving of information.

A IthinkthatImightquarrelwithyou,butI

understand what the basis of your question is.

Q All right YouunderstandA I think when people speak on background and

somebody says “A White House offkial said,” I wouldn’t &I

that a leak.

Q Okay. All right. Let’s confine it to background,

the.

A Oroffiherecord.

Q .Off the .vrd. And my question is are you aw&

of any effort to let’s say leak or disclose, again not saying

in and of itself that there’s a problem with that, any

efforts to leak or disclose off the record grand jury

information by anyone at or acting on behalf of the white

House?

3 A But the answer is no.

4 Q All right. You have talked about -- we were goin

5 chronologically last time and you talked about your

6 conversation with -- you were taking about what was going

7 on --

8 THE FOREPERSON: Just another five minutes and then

9 weneedtotakeabreak.

IO MR. WISENBERG: Oh, okay. Do you want to do it

1 now? I’mkindofatanaturalseguepoint.

.2 THE FOREPERSON: Okay. Why don’t we take a break?

.3 A little ten-minute break and then we‘ll be right back.

4 THE~TINESS: Tenminutes?

s MRwlsENBERG: Yes. We’ll unnegetyou m.

6 (Witness excused. Witness recalled)

7 .h4RWlSENBERG:Letthe~~flecttheWitnCSS,

8 John Podesta, has reentered the grand jury room.

9 Madam Foreperson, do wehave a quorum?

10 THE FOREPERSON: Yes, we do.

!l MR WSENBERG: Al% th% ally UMUthO& hUmaa

12 beingsinthegrandjuryroom?

13 mFORmERs0N: TImeare nounauthcukdbeings

+I period in ti grand jury room.

15 MR. WISENBERG: Okay.

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A No.

Page 38

Q~Okay:Hastheree~~been~occasianwhenaWhite

Houscs&csmanblamcdtkco~cforagrandjuxyleakwbcnyou

had information eithez first or &-hand that it wuxk3 from

somebody acting by or on behalf of the White House?

A No.

Q Okay. Are you aware of any effort to in any way,

&apeorformattaekthecnzdibiityofapersonbytbename

of Ashley Raines?

A No.

Q There was a story a while back early in the

investigation about Ms. Raines and what she did or didn’t

tell investigators. It had a line at the end that said

something to the effect of “Sourazs at the White House

indicated they’re prepared to attack her credibility” and

that’s the basis of my question. You have no knowledge of

any such effort?

A I have no knowledge of any such basis to attack her

credibility.

Q And do you have any knowledge of who might have

told that at the White House to -- and I don’t want you to

speculate, do you have any knowledge first or secondhand of

who might have imparted that information if anybody to --

A To a reporter?

Q Yes.

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Page 411

THE FOREPERSON: Mt. &ksta, you are still u&r

oath.

lXEwITNEss:Thankyou.

BY MR. WISENBERG:

Q Okay. We had been talking ehronologieally last.

timeaboutinstanaXiJltbecarlydaysaftertbePostartide

wbentbex%zsi~~~~theallegatioast.oyauinvarials

formsandwctaUcedaboutthre&suehineid&.s,noteumting

statennznts being cleared for lawyers. And we wuz also kind

of going along chronologically about how things wue

happening.

Are there any other instances *re the President

either denied to you any of the allegations about tbe

Lewinsky mat&r or where you Lard him deny to others,

excluding statements, press statements, you know, statements

on television programs and radio interviews, things like

that?

A I had one conversation with him, to go back into

thewe&,tbestorybreaksonWedne&y,wetalkedabout~

that,aadthenThursdayhedidsomepressandhehasaprtss

availability, I talked to you about my conversation on

Friday. I remembertalkingtohimoIlsundaybcforettlcs

of the union.

Q Okay.

A Andhewasina--we,Ithi&hadcomebyreally

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Page 41 Page 4

to get him to go over and to do a state of the union prep 1 lawyers and I‘m not going to substantively get into it.

2 session. 2 Q What do you actually remember about the words lx

3 Q Okay. 3 spoke at this Sunday prep session?

4 A But I think we also told him at that time that we 4 A I really remember more the tone than the words.

5 had arranged ourselves kind of in the manner that we have 5 don’t think he added anything substantively to the prwi01.1~

6 just been previously going over, that Chuck was going to me& 6 conversations I had had with him on Friday. He probably said

7 with the lawyen and tim we had a communications meaing, we 7 less, but it was a different -- Friday, I thought he was --

8 wrxego~toCrytoworkthroughthis,henaededto~tUp 8 youknow,hejustseemedreallydowaandwasn’tsureexactl

9 there. 9 whatwasgoingtohappcn. AndbySunday,Ithinkkwasback

0 You know, again, we’re trying to -- he was down 10 to, you know, the person I’m more used to dealing with

1 in those days prior to that. Keep your spirits up, the 11 Q AndItbinkyoubadsaidonFriday,tbereweretwo

2 stateoftheunionwasreallygood,thestu.ffthatwasin 12 umvexsations on Friday. I think one you wen: pretty 6

3 it was really good and that WC were kind of preparing to 13 was Friday morning and the other you thought was Friday

4 deal with that and how we would handle Stmday’s show and 14 afternoon,, but you weren’t as certain that it was on that

s thisandthat. IS day.

6 AndIrememberatthetimeinthatsettinghe 16 A Right.

7 hasicaIly had kind of a little bit of a change, I think, of 17 Q TherewasmoredetaiIinthoseconversationsinthe

8 spirit. IthinkheWaS --hesaidhehadhadthefnst 18 sense that -- or there was some detail. I think the one ir

9 decent night’s sleep he had had and that he was -- I think 19 the afternoon, I think, you uxr+ me if I’m wros you

o angry at that meeting and said - basically, I think, 20 mentioned the specifics about - when you got into the issue

1 repeatea the-denial and said “I’II fight this and we’re 21 of the press reporting the number of visits, he gave you

s going to get tbrougb it and I’m going to do this.” And his 22 respanst that had to do with Monica visiting Ms. Carrie, if

3 spirits were just sort of different. 23 yourecallandtheninthcmomin&Ithinkinthatmorning

4 I don’t think there was anything substantively 24 discUssion you had said he denied having sex in any way,

5 different, there were a couple more people in the room, but 25 shape or form.

Page 42 Page 4

1 that’s the only other - that’s a conversation I remember. 1 Sothere’ssomedetaiItherethatgoesbeyondthe

2 Subsequent to that, we’ve been_ largely in the -- 2 “I didn’t have sex and I didn’t tell her to lie.” And my

3 youknow,inthtmodcofdoingthiskindofQBtApnpscssion. 3 questiontoyouisistherearepetitionoftbemoredetaiI&

I We don’t talk about the specifics of the case. 4 stuff on Sunday or is it closer to the early-kind of more

5 Q Okay. What do you mean, Q&A? Prepping for 5 general deaial, “I didn’t have sex and I didn’t tell anyone-.

6 questions that would he asked - 6 to lie”?

7 A Questions, press questions. 7 A Ithintr%latter.

B Q Okay. 8 Q Okay.

9 A Here’s the questions - 9 A That’s my recoIIection.

3 Q About the Lewinsky matter? 10 Q Okay. Yousaidhewasangry. Whoorwhatwashe

1 A About the I_ewinsky matter or about the Independent 11 angry at, if you can tell us, on Sunday?

2 Counsel or about whatever - whatever is the topic du jour 12 A You - not you personally -

3 that the press corps is asking about. The&s always 13 Q Not me personally, but Judge Starr?

I something. 14 A Probably Judge Starr, but I think the blending

5 And we’re in a pretty standard “we’re not talking IS of the Paula Jones case which I think he always felt was

6 about this” mode, so from tbe perspective of briefing him, 16 motivated by people out to attack him and attack his

7 it’s more -- really, the goal is to let him know what 17 presidency and the Independent Counsel investigation and

B questions are likely to be shouted at him so they don’t seem 18 the kind of cross-over about those things.

9 surprising to him when k’s standing -- he’ll be making an 19 I think he thought it was unfair and, you know,

0 announazment in the Rosr: Garden and someone is yelling, you 20 he’s used to getting hit but I think some things he thinks

1 know, did you read Steven Brill’s article, what‘s your 21 are unf+ and I think he thought this was -- the blending

2 comment,be- 22 of these two matters was unfair.

3 Q He’lI be ready. 23 Q And he articulated that blending concern on Sun&y?

4 A He’ll at least have kind of heard the question 24 A I may be speculating a little bit, but I think

s before, but the standard response now is deferring to the 25 he - I think that’s his view.

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Q Okay.

Page 45

A I may he speculating a little bit about whether he

was that explicit in the conversation. As I say, the one

thingI=her about the conversation was that he had --

his mood had changed to some cxtait from being down and swt

of -- I don’t know a different word to express it, but --

about the story and where it was and, you know, his feelings

that it wasn’t true, but being‘- about how to handle it

really publicly, to one in which he was just a little bit

more -- he was angry, I think.

Q Okay.

A But I don’t specifically remember the language he

used or wbetber he said, you know, be pinned this on the OIC

Q Okay.

A At that time.

Q Has anybody other than -- I’m not interested in

getting at the content of any conversations you bad with your

lawyer through this, through what I’m going to ask you, but

hasaa~~outtoyoyanybodybyoronbehalfof

the White House sin= you got your first grand jury subpoena

talked to you about your testimony?

A Only about legal issues. I would describe it as

legal issues.

Q Whether or not to invoke certain privileges?

A Yes.

Page 46

Q Okay. Them was nobody other than your attorney

who you’ve discussed -- well, you’ve mentioned there’s a

matter having to do with Hilley, with information you got

apparently indirectly from Mr. Hilley or his attorney and

we’ve talked about that.

Other than that, has there been any effort to

dinzctly or indirectly talk to you by anybody other than your

lawyer about your testimony? By anybody whether with the

White House or not.

A Justreporters.

Q Okay. Other than reporters?

A No. And I haven’t discussed it with reporters.

Q AlI right. Now, are you part of an information

sharing wt? That is, have you authorized your

attomeytobepartofany agreRnent by which you share --

and I’m not suggesting one way or the other whether that’s

proper or improper -- to share with other attorneys

information that you have given either to our investigators

or to the grand jury?

A I’d have to check with him about that answer.

Q Okay. And, again, I’m not asking about the content

of that, but just -

A I understand.

Q -- are you part of that. What’s sometimes called a

joint defense agmment, but I don‘t want to get hung up on

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labels, so I’ll say information sharing vt. And I’ll

let you -- do you want to talk with your attonrey before you

answer that?

A Mm-hm.

Q And we’ll just defer that until right before we’re

done.

A Okay. Great.

Q I’ll defer that.

A So the question, though, was have you authorized

any information sharing agrcanent on behalf of myself with my

attorney?

Q Right. Have you authorized it or are you part of

any, wbenz you would be -- wbenz your attorney could teU

otberswbatyoubavesaidandyoucouldleamwbatothers

have said, without respect to what it is, you know, the

content of it.

Have you talked to anybody at the c~unsel’s office

about your testimony other than tbc issue of when you would

invoke the privilege? About tb= substance of your testimony,

expected or completed.

A I did not discuss the completed testimony. I think

that - I’ve told you &ve bad discu&cms about whether to

invoke initially executive privilege ad then attomey-dient

privilege and there’s been some texture to that dieon,

but that’s it.

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Q Okay.

Page +C

A So if.you're excluding those conversations, I thinl

the answer is that I don’t recalI any other conversations

Q Okay. Texture, define texture.

A Well,whenIwaslasthere,wehadonespecific

meetinginmindandtherewas-sinaIalready,Ith.inl

identified that Mr.&fT was part of that meet& Mr. RUR

knewwhatthemeetingwas,sowttalkedaboutthatanc

whethertherewasaprivilegeq?lestion.

Q oh, the July meeting, you’re talking about?

A yes.

Q Okay.

A Imean,so-Imean,Ithinkthatyoucan’tdo

this completely in an abstract fashion.

Q

A

Q

bit.

A

Q

A

Q

A

Q

A

Completely theoretically.

tight.

Okay. Bruce Lindsey, we talked about him a littl

Mm-hmm.

He’s a senior advisor to the President.

correct.

And a member of the counsel’s office.

That’s correct_

A long-time friend and associate of the President.

Right.

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Page 49 Page 51

1 Q What discussions have you had with him since the -- 1 attorney.

2 let’s go back chronologically. You told us about your 2 A Right.

3 discussions with him on the day of the deposition, both with 3 Q And we‘ve talked a little bit about the approach

4 Ms. Mills and then later with Mr. Lindsey. What discussions 4 from the Hilley people. Have you spoken with anybody else

5 have you had with him about the Monica Lcwinsky matter since 5 ahout -- or has anybody else spoken with you about since thi

6 thattime? 6 story started breaking -- I’ll say since the Saturday call

7 A Other than his participation to some extent in 7 of the deposition -- about those three areas?

8 these press meetings, I don’t recall having any other 8 A I don‘t recall having any conversations other than

g specific kind of fact hased coaversations with him. Now, he 9 reporters asking me and my not answering.

0 sits in sometimes, he’s been ill for a while so he hasn’t IO Q Okay.

1 beentbaeverymuch,hutsometimesbesitsinontbekindof II A I don’t think so.

2 public relations -- what I’ve described as public relations 12 Q Okay. Has the President of the United States in

3 meetings. 13 any way, shape or form talked to you about any of thos

4 Q And those meetings don’t have directly to do with 14 incidents, those three incidents?

5 John Podcsta issues individually, correct? 15 A Yes.

6 A That’s correCt 16 Q Okay. Tell us about that.

7 Q All right_ So your conversation you talked about 17 A we had just nominated Mr. Richardson -- we didn’t

8 last time that you spoke with him after the deposition and 18 norninae him, we just announced our intention to nominate

9 you mentioned that thue had been questions ahout Monica 19 Mr.RichardsontobetheSecretaryofEnagy,andwr:hadan

0 Lewinsky. Is that correct? 20 extwlely brief conversation about this in which -- and I do

1 A Yes. 21 alotof perxmnelstuffandIdosomeoftheconfiirqation

2 Q That’s the last substantive conversatioll you’ve had 22 issues.

3 with him about the Monica Lewinsky matter? 23 And1.saidtohimaswewerediscussingthemerit.s

4 A IthinkSO. ThatICanti. 24 of the &ha&on nomination that I thought that the I&win&

#5 Q Allright. 25 issue - I don’t think I probably said much more than that --

Page 50 Page 5:

1 A I mean, again, other than this kind of group 1 was potentially a question that would be raised in the

2 meeting context in wl@ch Bruce rarely says anything. 2 context of his confirmation bearing.

3 So I don’t remember him saying anything about it &d 3 And hc said to me, he said, “Well, as I understan<

4 I wouldn’t describe that 8s a conversation between the 4 it,” and that was from reading the m,.hc said, “He

5 twoofusrealIy. 5 didn’t do anything wrong, did he?” And 1 said, “I d&‘l

6 Q Thekindofthreethings,threeanzaswhere 6 think so, but you should get a briefing from Chuck ahout thal

7 you interfaced, not personally, but in the broadest sense 7 ~dyouandIshouldn’tdiscusstbefactsofthismatter. It

8 of the wor4 with the concept of Monica Lewin&y prior to 8 would be better to deal with Chuck on that.”

9 the calls you got on deposition Saturday, we’ve talked 9 And then we discussed the me& of the Richardson

0 about those, the first is the mess&e from Bowles to the 10 nomination from his cxpczia~cc in New M&co and what k was

1 President in -- I think you said it was in the late spring I I doing at the U.N. and who were going to replace him at the

2 of 1997. 12 UN. with, but we had a kind of fleeting conversation ahout

3 A Yes. Late spring, early summer. I can’t place it 13 this. .I pointed it out as a place where there could be an

4 exactly. 14 issueinaconfumationfightandsuggestedthatbetalkto

5 Q Right. The second is the Betty Cunie approach IS Gounsel about it. Factually.

5 that led to your approach to Bill Richardson. 16 Q Did you specifically discuss anything about your

7 ACorrect. 17 interaction with Richardson about Monica Lcwinsky?

6 Q And the third is the John Hilley assignment from 18 A IthinkthiswasasentenceortwoworthandI

J Erskine Bowles. 19 don’t remember more than really what I have just said. You

3 A Right. 20 know,thatIaskedhimwhetherhe-Imayhavesaidthat1 Q You’ve talked about a brief conversation with 21 but I don’t even think I said that much.

2 Mr. Bowles along the lines of “I don’t think we did anything 22 Q What you’re telling us today, and this is, I take

3 wrong.” 23 it, fairly recently -

4 A Right. 24 A I think he knew what the issue was, it’s fair to

5 Q And I’m not interested in conversations with your 25 say. I mean, there’s been a lot of press about it But I

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1 identified it as an issue that could be a controversy, that

2 he could be questioned about in the context of confirmation

3 hearings, but we didn’t discuss the merits of it or what 1

4 knew about it or what I did

5 Q Okay. I think you said there’s been some press

6 about it, about the fact that you went to Ambassador

7 Richardson on Ms. Lewinsky’s lnrhah?

8 A Well, I probably wouldn’t characterize it that way

9 but, yes.

0 Q Or on Betty CUtTieS’ behalf?

1 A Well, I’ve testified to this.

2 Q I know you’ve testified to it, but has there been

3 press about it?

4 A Yes.

5 Q Okay. And the -- I mean, I Imow the ambassador

6 issued a statement very early on about it also, some kinc

7 of a statement about Ms. Lewinsky. So I take it your

8 assumptionishekaewwhatyouweretalkingabout,buttbere

9 was no .sp&flC reminder to him or discussion, you know,

0 “Mr. PIV+ent nzmember I had a conversation myself with

I Ambassador ~I&hardson about Ms. Lewinsky.”

2 A Ithinkthiswastransactedinasentenceortwo

3 andIthinkheknewwhatIwastallcingaboufIknew~atI

4 was talking about, and I think he said, “Well, be didn’t do

5 anything wrong, did he?”

Page 54

1 And I said, “Look, you and I shouldn’t have a

2 factual discussion about this. You should deal with Chuck_ or

3 it.”

4 Q All right Any other time that you have spoken

5 with the President about these three Monica related events in

6 yourlifethattookplaeebefoteMonieaLewin&ybecamea

7 household word?

B A I don’t think so, but I’m cautious about this.

? Q To the best of your recollection.

3 A Tothebestofmyrecollection,Idon’tthinkso.

1 Q All right. Have you heard of the talking points?

2 A Yes.

3 Q Do you know either f&and or through secondhand

4 or thirdhand who wrote them?

5 A No.

6 Q Did you write them?

7 A No.

B Q Okay. You know what I refer to, though, when I

9 talk about -

3 A You’re talking about the Linda Tripp/Lewinsky set

I of talking points.

2 Q Right.

3 A No.

4 Q Have you ever seen a copy of them?

5 A I think they’ve appeared in the newspaper.

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3 Page 55

I Q Okay.

2 A I’m sure they’ve appeared in the newspaper.

1 3 Q Okay.

4 A And that’s the only context in which I’ve seen a

5 copy of it.

6 Q All right. And you have no idea who authored

7 those?

z Re: GJ Proceedings

, 8 A I have no idea who authored those.

9 Q I believe you testified that you’re old friends

I10 with Ms. Cunie.

II1 A That’s correct.

1 I2 Q You all go back how far?

I13 A I think we met in ’ 78 and we worked closely

I14 together then.

II5 Q And that was in the Carter administration?

1116 A Yes.

117 Q That was at ACTION?’

: 118 A Yes.

119 Q And ACTION controlled, amOng other things, VISA -

2!O A VISTA, Peace Corps. At that time, it was - Peace

2!I Corps is separate now, but it was VrsTq Peace Corps and

2!2 Older American Volunteer programs.

2!3 Q And what was her position there?

2!4 A Sk was the executive assistant to the director.

2!5 Q Okay. Is that a similar position to what she has

I Page >c

1 now?

I 2 A_ Yes.,

3 Q Okay. Lot of responsibility?

4 A Yes. I mean, she’s kind of a top level-executive

5secretary.

6 Q Okay. Very competent at what she does?

7 A Ye&

8 Q Okay. Considered to be an intelligent person?

9 A Yes.

1 0 Q Capable?

1 1 A Yes.

1 2 Q Okay. How would you describe her reputation among

1 3 the people you work with?

1 4 A Excellent

1 5 Q As an overall matter, excellent?

1 6 A I think people are very -- both professionally and

1 7 personally, very attached to her.

1 8 Q Okay. What is her reputation for truth and

1 9 veracity?

20 A High.

2 1 Q How close are you with Sidney Blumenthal?

2

2

2 A I’ve known him a long time. I used to work w ’

3 his wife and I would say we’re friendly. Friends.

4 Q Okay. Not close friends?

5 A We’re not close friends, but we’re friends. 1 sort 1

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I of get a kick out of him. He has a new theory about all I discussions you’ve had with the President -- I think you’ve

2 this. 2 now identified four conversations with the President,

3 Q AIl right. Okay. Did you ever have a 3 he gave denials in various forms. Again. not counting on

4 discussion -- well, you’ve kind of answered my question. I 4 signing off on statements for the press or any press

5 was going to ask you have you ever had a discussion with him 5 appearances wbcrc you saw him; four occasions where be.

6 about the Monica Lewinsky matter. 6 gave denials, the President gave denials. Do you know

7 A Yes. 7 whether or not Mr. Blumenthal was present for any of

8 Q Okay. Let me distinguish between factual and 8 those?

9 press, the kind of discussions you’re talking about. I think 9 A I’m fairly certain he wasn’t

0 you’ve mentioned be’s at the meet@s. Is be at the meetings 10 Q Okay. I think two of them you were alone with the

Isometimes? 11 President. Isthatconect? TbeccnveMtionsthatwenzon

2 A Yes. YeS,Sometimes. 12 the23rd3 Q Letmedistinguishbetweenkindofstrategyand 13 A ThefirstoneIwasdefiinitelyakmewiththe

4 facts, not that they’re mutually exclusive. Have you ever 14 ~~tandtbesecoadone,myrecoUectionwasitwasa

5 hadafactuald&cussicmwithhimabouttbecaseinwhichhe 15 kindofone-oosnecon~tion,butIcan’tremember

6 related to you some&&& for in&ma& just as an example, 16 whet& -- sometimts, you know, in the Oval Office you can

7 “I saw Monica Lewinsky at the White House on three 17 havea one-on-one conversation where there are other people

8 occasions.” Have you ever bad that kind of a conversation 18 in theoval Office.

9withhim?- 19 Q Allright. Sowoulditbefairtosaytheonlyone

0 A I don’t think I’ve ever spoken with him factually 20 he might have been at was the fourth one you’ve talked

1 about Moti&LewiIlsky. 21 about -

2 Q Or about the Monica I&win&y matter. 22 A No, I don’t think he was there. I mean, he could

3 A Well, the only thing-that I can recall is after one 23 have been, but I don’t --

4 ofhisgrandjuryappearanceshesaidtome~--hesaid, 2 4 Q AlI right. You have no recollection that he was

5 “Your name came up in my grand jury testimony.” I said, 25 there.

Page 58 Page 6(

1 “Oh?” He said, “I said you were a law professor.” And I 1 A I’m fairly certain he wasn’t there, but I’m not

2 said,“Thanksalot,Sid~ And.tbat,Ithink,wastheendof 2 100 percent certain he wasn’t there.

3 that converSation.” So I guess that constitutes facts: 3 Q Andyoutalkedtohimabouthistheor-iesofthe

4 Q Al.l right. ‘Ihere’S no Other factual ConverSatiOn 4 case.

5 you’ve had with him. 5 ARight.

6 A WelI, that’s kind of a broad question. 6 Q You am not responsible for his niclmame GK, are

7 Q Yes,itis. Letmetrytomphraseit. Anykind 7 you?

B of- 8 A No.

3 A H&s never given me -- 9 Q Okay.

3 Q Evidentiiuy. 10 A I don’t know if anyone’s taken credit for it.

I A - evidemtiary informatiou, I think, about the 11 Q Okay. And, again, the general questions you’ve

2 underiying facts of this. 12 answmd previously about what goes cm at the meetings, the

3 Q Okay. All right. 13 brief- that you’re aware of or apparently primarily not

1 A He spins a lot of theories about kind of what’s 14 aware of testimony, you have no particular -- they would all

5 going on. 15 cow Mr. Blumadal, too, since k works at the White House.

5 Q He’s never said, “I’ve talked to Bruce Lindsey and 16 Any questions I’ve asked you about what people -.

7 Bruce Lindsey says this about what was going on with h4onica.” 17 dc you know of any paopk acting by or on behalf of tkWld

3 A NotthatIrecallatalI. 18 House, things like that. I mean, Blumenthal works at ttX

3 Q He’s never said, “I’ve talked to Vernon Jordan and 19 White House, your answers would cover him, too.

) Vernon Jordan says this about Monica.” 20 A To speak to witnesses? Is that the question you’re

I A No. 21 asking?

2 Q Has he ever said, “I’ve talked to President Clinton 22 Q As an example, debriefing witnesses, things like

3 and President Clinton says this about Monica lewinsky.” 23 that.

4 A No. 24 A I don’t think he’s done that, but 1 don’t know.

5 Q Okay. Was he ever present in any of the 25 Q Okay. All right. You’re unaware of him having

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1 either debriefed or gotten information about the debriefing

2 of witnesses. Is that correct?

3 A Yes.

4 Q All right. And I take it you’re unaware of him

5 making any disclosures to anybody about what witnesses hav

6 said to investigators or to the grand jury. Is that correct

7 A That’s correct

8 Q All right. Do you know of any interaction he might

9 have had with any private detectives?

0 A No.

i Q Do you know of any private detectives hired by 01

2 on behalf of -- other than what you’ve mad -

3 A Sidney’s got his own case going, so I don’t know

4 what he’s done there.

5 Q What do you mean by that?

6 A He’s suing Drudge.

7 Q Oh, okay. Okay.

8 A So I have no idea what he’s doing there.

9 Q Okay. All right. Are you awareof -

0 A That’s on a separate matter.

1 Q Right. Right. A libel matter.

2 A Alibelmatter. Right

3 Q Have you - are you aware, other than what you%

4 readaboutinthepressorheardaboutinthepress,awareof

5 any efforts by or on behalf of the White House to hire

Page 62

1 private investigators with respect to the Lewin&y matter?

2 A No. I have read in the press about that and there

3 was some back and forth about what IMcCuny cadd say about it

4 andthenhehassaidwhathehassaid.

5 Q Au&@-

6 A And that’s basically all I know.

7 Q Allright. Soyoulmowwbathesaidandyouknew

8 there was a discussion about whether he could say that.

9 A Right.

0 Q All right. One of these discussion!z with press

I people and lawyer people?

2 A Yes.

3 Q Okay. And, if I’m not mistaken, be said something

4 to the effect of there had been some -thexe have been

5 some --

6 A Ithinkhesaidtherehavebeenno--Ithink--

7 my recollection is a little hazy. I think we’ve said that

8 there have been no lawyers hi& to investigate prosecutors.

9 Q Okay. About private matters?

0 A Maybe about private matters. I don’t know.

I Q All right. You don’t know anything beyond -- yol

2 have beard no facts beyond what Mr. McCurry’s statement is.

3 A Correct

4 Q Okay. Have you ever had any conversations with

5 the First Ladv about -- let’s first confine it to the

,Pagem Tuesday, June 23,1998

Page 63

1 evidentiary -- evidentiary type conversations with her

2 concerning the Lmvinsky matter?

3 A I’ve not had any conversations with her, I think

4 about the evidentiary matter.

5 Q Okay. Has she been involved in any strategy type

6 discusSions or any of these - well, let’s just leave it at

7 that.

8 A She does not participate in any of these meetings

9 and I don’t know that she’s participated in any kind of

10 strategy discussions with the group of people I’m talkin!

I1 about

I2 Q Okay. What is her role, to the extent that you

13 knowofifin comxction with the Lewi&y matter?

I4 A I’ve had a couple of brief conversations with her

15 andIsuspcctshemayhavetalkedtootherpeopleint.besame

16 vein that, you know, people neeckd to stay pumped up and get

17 out there and fight back and just essentially, you know, what

18 I would &s&ihc as sessions in which, you know, she’s

19 axoumgaiustonotjustbunkerdowand,youknow,beproud

!o ofwhatthePnzsidmtwastryingtodofortheamntry,get

!I out there and talk about it.

!2 Q Okay. Who would you say is in charge of the

!3 political effort on the Lewinsky matter, responding in the

!4 press politically? Who is in charge of that?

!5 A I think ultimately it‘s Chuck.

Page br

1 Q Okay. All right. ChuckRufE

2 A Yes. Imean,thereagain,thisissortof-to

3 some extent, it’s kind of a collegial effo& I guess, and i

4 dependscmthepatticularissueorthcpartieularma#cror

s theparticularweek Butallofusparticlpate,Begala,Ann

6 L+s,RahmF%nanuel,myself,butin&nsofwhatcanbe

7 sai~whatcan’tbesai~intbeen~chuckllasthekindof

8 final say on that.

9 Q Okay. But there is this division where on a lot of

o the things having to do with it it’s lawyers only, correct:

1 A That’s correct.

2 Q Would you characterize yourself as close to the

3 President as Mr. Blumenthal is on a personal level?

4 A Idon’tlrnowhowcl~heistoMr.Blumenthalona

5 personal level.

6 Q Okay. Based on what you know.

7 A I feel like -- I’ve known the President a long

8 time, we have a close relationship.

9 Q Okay. As far as you know, it would be as close itl

!o his relationship with Mr. Blumenthal?

!I A Yes. I think I have a different sort of

12 relationship with him than Mr. Blumenthal.

13 Q Okay. How so?

!4 A Well, I think it’s by the nature of my work, I

!S suppose, which is mostly I deal with him in a professional

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1 way, on a kind of -- you know, a kind of series of trying to 1 THE COURT REPORTER: I didn‘t steal it.

2 nmtheWhiteHouse. 2 (Laughter.)

3 IthinkSidtendstospendmoretimewithhim 3 MR. WlSENEERG: I want to distinguish between th

4 about, you know, big think projects and, you know, kind of 4 writing that is previously on t.hz that you haven’t written

5 chit chats with him a little bit mom about, you know, the 5 and anything new that I have you write a ~DP-2 and I might

6 future of the world than I do. 6 not have you write anything.

7 Q AB right. 7 THE wlTM%S: Okay.

8 A I kind of grind it out more. 8 BY MR. WISENBERG:

9 Q Okay. What about the First Lady? Do youknow 9 Q I want to focus on the hallway which is labeled 01

o wbetber or not -- would you consider yourself as clost-~ on a 10 ID&2 HI bctwm tbc Oval Office and the dining room. Do you

1 personal level with the First Lady as Mr. Blumenthal is.7 I1 see that there? It says Hl on JDP-27

2 A I think he probably has a closer personal 12 A uh-huh.

3 relationship with her than I do. But I have a warm and 13 Q It should say that.

4 friendly relationship with the First Lady. 14 A Yes. Right.

5 MR. WTSENEERG: Let me show you some stuff. I5 Q And the study is off of that hallway and the

6 I think we’re near the end, if you’ll have a little 16 hallway leads -there’s a hallway between the dining room

7 indulgence here with me. 17 and the Oval Office. Is that correct?

8 THE FOREPERSON: It’s there. 18 A correct.

9 MR. WISEMBERG: It is them? Okay. I will just 19 Q What I want to ask you is how do you typically gl

o speed things up very rapidly. 20 intoseethcPresident? Doyougot.broughtbeafeawbexe

1 Let me give you what’s been marked as JDP-1. It’s 21 Betty Currie is?

2 acopyof~‘sbeenmarkedasJDP-Ifmmyoutearliergrand 22 A Yes.

3 jury testimony. 23 Q Okay. Where there’s a EC?

4 And let me also give you JDP-2, something I‘ve 24 ARight.

s marked as JDP-2. 25 Q And go tiough.the door &at if the Oval (%x m.s

.~-

Page 66 Page 6E

1 (Grand Jury Exhibit No. JDP-2 I a clock it would be the 1:00 door?

2 was marked for identification.) 2 A Yes.

3 BY MR. WISJZNBERG: 3 Q Okay. Howoftendoyougointothe(~~~~Office

4 Q They’rebothmapSOfthe-~~tObemapSOf 4 tbfou#lcithuthc11zoodoorupthrou8hwaIkwayaur~~: 2ar

5 the west wing. Is that correct? 5 through this hallway Ilumber 1 which would be 8: ,?OO o&be

6 A Yes. 6 Oval Office?

7 Q JDP-1 of one floor of the West Wing, the floor the 7

8 Oval Off& is on. 8

9 A Yes. * I

0 Q Jrx-1basonlyonemarkingmadebyyouprevious1y IO- y

I and thats in the ’ room labeled 108. You have written down 11 . ,.. .-

b *

2 your initials. Is that correct? 124 ’ I” 1

3 A Right_ I didn’t know it had a room number, but, 13 w

4 yes. J4 Qm

5 Q Okay. And JDP-2 has some writing, descriptive 15 A ‘Ill _

6 writing, about certain of the rooms. 16

7 A Right 17-

8 Q And that was not made by you, that descriptive 18 Q I *-

) writing. Is that correct? 19 A(- 1

) A That is correct.

I Q IthoughtIhadleftaredpenforyouupwhereyou21 -

I are&

5 A I have a green pen. 23 ‘*” ’

I MR. WISENBERG: I had two -- oh, the court 24 Q Okay. And --

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2 Q All right. And you go in, your l.~$al way --

3 A Would be through Betty’s offict

4 Q Okay. Of the times that you go : ? the Oval

5 Office, what percentage -- and I take ii : w go in very

6 often --

7 A Yes.

8 Q What percentage of the time do ’ >:l. go in through

9 the 1:00 door, the Betty Currie door?

0 A Ninety-five.

1 Q Okay. Do you ever go in by go:1 lhrough the

z dining room and through this hallway fro; c dining room tc

3 the oval Office?

4 A Yes, but that would be on rare occasion. And,

5 generally, because something going on in the. dining room.

6 Q Okay. Something’s already going ‘Jn in the dining

7 room.

8 A

9 Q

0 A

1 Q

2 A

Right

Some event.

Or_ !hcr@s going to be some event.

Allrightyou know, sometimes we’ll brief him ‘II the dining

3 roomandwemightenter--tl&ismarked; itwast%orge

4 Stqhanopoulos’ offke, now it’s Rahm .Em 1 aeels’ office, if

5 there is some briefing going on in the dininr room or there’s

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to be a briefmg that’s going to happen in tl’, dining room,

~lythathappenswhenthere’ssomet~~ 1’ %gedinthe

Oval, I might go through Rahm’s office if:’ ‘re dining room

and then if you have to go get the Presicir I-. cause he’s in

the oval office, you ,?>‘<.M go through r1,; 2 3, Butthat

would not be a “>ijir-, ’ .=iy I T:.rould erc

Q All right. And /m‘ dicn’t‘ he\ &kindof a

situation that you’d:: j; .kscri:~~I. :i \v’Iicc, ,karebeing

t&fed in &e d&i c:. ,-’ -r?& thes’ goi, ~’

that happens in tile CL,. 1 ~3fike., you wouJ<

be somethbg

cntertbrough ‘

that way.

.4 That’s correct

Q Could yoc _;::r _- -;: down right :I! 1-8 of GS - I

guess it would be I?

A h&-hmm.

Q Because that’s mm Rahm Emanvcb‘ off&.

A Right.

Q That’s jusf :c “?? !cTt of tlx dini: _ gm,

correct?

A hb-hmna.

Q And is +&at t:j-t_zlly what p=.np!c ,‘e to do in the

White House, including .>: Chief of St&, ;ir advisors,

that the typjczl v T:; t’.~ ; CciX through is ” .:&I the Betty

Currie entrance?

A Yes. It would k typical. Yes. A<;. Bowles is a

Pagem Tuesday, June 23,199%

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little more - you know, I think, at ease on walking in on

~whetherit’sintheresidenc+orhne,soifhewantai

to, be could probably go the other way, but I would think

that -- but I think if you asked him that same q&on, he’d

probably say 90 percent or 95 percent of the time he’d go in

that way.

Q Okay. There’s nobody that you know of in the White

House, and I’m excluding the First Lady, is then anybody you

know in tbe White House who would - well. h me not exclude

anybody. Is there anybody you know in the White House wh

typically enters through that hallway to go see the

President?

A Which hallway?

Q Hallway l,betweenthediningroom-Hl onymu

map between the dining room and the Oval Office.

A I don’t know Rabm’s pattern. I would say it would

be typical for him to go in through Betty’s office, but L

may -- aii those offices am conne&ng. Rahm’s office

umnectstotbediningmomwhichconne& totllellallWay

which connects to the Oval Office.

Q Okay.

A And then my office is next to Rahm’s, but it does

not conmt. There’s no connecting door.

QRight.

A So I have to go out anyway.

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Q DoyouknowwhatA And I don’t know whether ix goes in that way or

IlOt.

Q Okay. All right

A ButIwouldthinkthatbeyondRahrqthatwouldbe

about it. And I don’t know what George’s pattern was with

him either.

Q why is that atypical for people to go through that

hallway, the dining room and the hallway?

A Well, first of all, it’s like the back corridor.

Q Okay.

A But also I think there’s a kind of protocol that

you don’t - you know, you don’t come u&3.9 you’= am~ounced

sort of.

Q Is the study considered a private area for the

President?

A YtZS.

Q All right. And is that generally true of the whole

are+ the dining room, study, hallway, Oval Office? They‘re

among the most private areas in the White House, in the

office part of the White House?

.4 I think the terms of use -- for example, Presidc

Bush, I think, used the study as his+xivate study. I think

the. President tends to -- he’ll be back there once in a

while. I’ve talked about a meeting where I saw him back

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there, but he tends to use the Oval Office more.

The dining room is used -- I mean, he has lunch

with the Vice President in there once a week. I mean, hc

uses it as a din@ room. And kind of as a briefing room.

To give some context to this, when the President

does a live radio address, he does it in the Oval Office.

Q Okay. What do you consider -- exclude the

residence, what do you consider tbe most private room in the

office part of the White House? If you bad to pick tbe most

private room.

A Well, I think basically the area we’re talking

about, but I would probably include the Oval Oflice in that.

I mean, obviously when he’s not thexz, the door’s open and

people look in, but --

Q Right. And you said the area we’re talking about,

that would be Oval Office, dining room, study and the

hallway.

A Right.

Q Okay: What about this area, and I’m near the Vera

~~whataboutthisareaoutside--Idon’treallythinkyou

can see it well on the map, but the area outside of the

study, the patio area.

A Patio 1 and patio 2?

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Q Right. Howprivate are those? Imean, is

everybody just allowed _to walk back there? Is anybody just

auowedacceSStothatarea?

A No. I think - I’m not sure v&&r there’s an

agentpostedbackthereornot. Andinteamsofthepatio,I

think they’re not particularly well used or weU trafficked

Patiolistlle-tbere’stlle swimming pool which is b&ind

someshrubsandpatio1isthe~~pointof~toZo

tothe!z&nmingpool.

For example, after the President hurt his leg ? rrd

stoppednmning,heusedtoswim,he’d.swiminthatpool.

If I needed to go see him, I’d go out through the diinrng

room, through the patio, to go out to the pool. Bui -,t.her

than that, I don’t think it’s particularly well used, much

used.

Q Based on your knowledge, would you call that a

restricted area, patio l?

A Well, I don’t think -- you know, people don’< go

out and have lunch out there.

Q Okay. All right. The Orkin man isn’t there

spraying on a regular basis?

A Actually, wrong question because there’s just a

little -- my office has a window that’s on the -- there’s

flowers back there and in fact -- there’s not a patio out

there, it’s just like a foot and there’s some flowers behind

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Page 75

it, and tbe Park Service people are the people who one would

most routinely see back there taking care of the grounds.

And also cm patio 1 and on patio 2. And tbey have pretty

free access back there because sometimes we’ll go out --

patio 2 is tbe Chief of Staff’s patio, which Donald Regan

built and if we’re out there, sometime-s we’ll have a meeting

out there if it’s a nice day or something, and in fact

there’s fairly often foot traffic back in this area

Q h the patio 2 area?

A And the patio 1 area. I think there’s an air

conditioning thing or something, I’m not sure what it is.

Okay. Between the two of them?

Betweenthetwoofthem.

All right.

By Park Service personnel during the day.

Okay. Tending the flowers and things like that?

Yes. Tending the shrubs and flowers and things.

Okay. Are you --

So in that sense, I don’t think it’s restricted.

M R. WISENBERG: Okay.

A queStiOn here?

A JUROR: Are the windows in the White House

treated in any way so that you can easily see out but not

have someone see in?

THE WI-DIESS: No.

Page 76

1 A JUROR: So someone standing outside, say, the

2 dining room campkx or the study complex could easily .sa. in?

3 THLWITNESS: Yes.

4 MR. WISENBERG: Are you -

5 Oh, I’m sorry, did you have something else?

6 A JUROR: There iS another qWStiOn.

7 MR. WISgNBERG: Sure. I’m sorry.

8 AJUROR: Doest.he&SidentUSUaIIytakenapSin

9 the study room?

0 THE WITNESS: No. I don’t think so. He may on

1 occasion, but I don’t think so. If be’s talking a nap, which

2 he does, he usually goes back to the residence.

3 A JUROR: He goes back --

4 THE WKNEZSS: To the residence. Yes.

5 BY h4R. WISENBERG:

6 Q Isthereaperiodofdowntimeduringtbedaywbere

7 he-likehegetsanhourorsojusttobeonhisown?

8 A Generally, we have what‘s called phone and office

9 time which we try to preserve three or four hours.

0 Q Oh, okay.

1 A And that’s time when he works in the Oval, makes

2 phone calls, plays golf if he can get away. Goes back to tbe

3 residence. Again, especially after be hurt his leg, he. did a

4 fair amount of physical therapy during that time period.

5 Q Any set time of the day --

Page 73 - F?age 76

_- Diversified Reporting Services. Inc. (202) 296-2929
3332

In Re: GJ Proceedinrrs Iblulti-:PafzeTM

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Page 77

A And that would be back in the residence.

Q And this question is from the time you’ve co ’ hack

totheWhiteHousein’97,anysettimeofthedayt..~he

would typically be in the study?

A No. Not set. No.

Q But he would be in there sometimes?

A Yes. I would say -- sometimes. He more often uses

the Oval.

Q Are you aware of what these -- are you personally

awarcofwhattbese-I’ltcallthanOrkinpcopt~:.,.N~~

people, Park Service people -

A Theyre ’ Park Service employees.

Q Are you aware of what these Park Service people, of

where they’re stationed in terms of like !&ret .&vice

policy, tithey go, where they’= allowed to go, depending

on what rooms the President is in?

A I don’! know.

Q You said that you believed the President H .cn he

made his denials to you

A Yes.

Q That was important to you, that denial?

A YeS.

Q I take it you would be - would it be fair to say

you would & -mxmed, upset, bebayed, if you for ’ wt

that the denials were wrong, were false?

--

Page 78

1 A I believe him.

2 Q Okay 4nd if you found out that he had ‘. T%!

3 telling you the truth, would that affect you in z, kvay?

4 A You know, I’m sure it would, but --

5 Q h other words, it was not pro forma to y your

6 view of the denial. It was important to you that hc ied

7 this.

8 A Yes. And it was not pro forma_

9 MR. WISENBERG: I’m going to a!& you to ?p

o outside briefly. We might not even ask you ba: ;il.

1 THE WITNESS: Okay.

2 MR. WISENBERG: If we do, it will be ver i&y.

3 THE N~S: Okay.

4 MR. WSENBERG: I’m sorry, I didn’t !:@ : !land

5 up.

6 A JUROR: Yes. I’m sorry. Just to follow VP on

7 that question,

8 In an) af the four conversations that you : with

3 the President in which he made these denials, (‘ ,.. ever

3 suggest that Ms. Lewinsky might have come OIL to I I tried

1 to initiate some kind of contact or relationship? Any citing

2 like that?

3 THE ums: I mentioned in the converb ‘.!n on

4 Friday morning he said that he wasn’t sure how he ...I ever

5 show that what he was saying was true and I think beyond

Tuesday. June 23.1998

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Page 79

that, he never really has -Ithinkhenever--heandI

have never had that conversation, but I think he had been

advised not to have the conversation by his lawyers and 11

sensitive about not exchanging information because I knew I

was a potential witness. So I think we have not communiclted

about the facts of this consciously.

BY MR. WENBERG:

Q But as I understand your testimony, in this

conversation on the morning of the 23rd, be voluateenzd this

information to you. Is that correct?

A Hedid

Q As well as the information later that i&moon.

Is that correzt?

A That’s light.

(Witness excused. Witness recalled.)

MR. WISENBERG: Let the record reflect the witness

has reentered the grand jury room.

Madam Foreperson, do we have a quorum?

THE FOREPERSON: Yes, we do.

MR. WISENBERG: Are there any uMuthOIiXd pasOnS

present in the grand jury room?

7HE FoRfw3so~ There are no unauthoriizd.pzzsons

in the grand jury ~obm.

Page bU

1 MR. WZSENBERG: ‘Ihank you.

2 THEFOREPERSONZ Mr.Podes@youarestiliUnder

3 oath.

4 THEWITNESS: CQrrect.

5 BY MR. WISENBERG:

6 Q Okay. Youwanttospeaktousonthequestion

7 about the inform&on sharing?

a A Right. I’ve been just advised by my counsel that

9 the answer to that question is itself privileged.

0 Q Okay. We won’t revisit that right now.

1 A Okay.

2 Q Now, I had another question. You had mentioned

3 last time when you were talking about --

4 A Icoulddoacasebookontheprivilegeissues.

5 Q You say you do? You have one?

6 A I said I probably could start one.

7 Q YoumentionedlaSttimewbenyou~talLirrgabout

8 the conversation on the morning of the 23rd thai tk:

) President had denied -- you mentioned to this effect, and you

) correct me if I’ve got it wrong, the Pxcsident denied having

I sex in any way, shape or form with Ms. Lewinsky, includine

I oral sex, but he said something to the effect of “I dor

5 know how I could prove that.” &her than --

t A Or show that. I don’t know if he said prove.

j Q Or Show that.

Page 77 - Page 80
3333

In Re: GJ Proceedines Multi-Pagem Tuesday, June 23,1998

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A Right.

@age 8’

Q I guess other than the gencl ,’ Droblem that anyom

has with proving a ncgativc, have you w: .xzcd about what k

meant by that?

A I think that -- I’d just be spet:ulating about this,

but I think that it was an issue of coving a negative in

context io which Ms. Mnsky was be+, pnss-a% my tern. to

give testimony, threatened with indic :cnt, and if she said

that she did, it would be hard to prove that she didn’t.

You know, that there was SC rt of a -- I think we

operate, this is my opinion, not h~j “pinion, I think we

operate under a presumption of p : t::, that unless you ca

prove you absolutely didn’t do it, evclybody sort of assumes

you’reguilty. AndIthinkhewasjustkindofreflectingon

that.

Q You were mentioning Mr. Blumenthal’s latest theov.

Tell us, if you can -- well, I don’t know bow long it would

take to go through it --

A We&I’ll do the quick version.

Q Okay .

A Hk’snoticedthatAirForcel >I-‘AirForce2have

goneoff,Ithinkthishasactually :S:jeadybeenreported,

that they’ve gone off the radar screen &g into LaGuardia

recently and that that usually precedes: a claim that there’s

ken an alien abduction and that we ! I Le’ a new theory or a

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Page 82

new defense that this whole matter i.c: -. irnehow linked to al&

abductions, but I think thpt’s pro; ,!Y the Iesult of ‘TIN

X-Files” being previews,. r!:is week l.lt with Sidney you’re

never quite sure whetlxx ic believ: hes just ’ kidding.

I think he was just kid6 1x2.

Q This is one .reasozs why I c ?sk you when you

come back in a~& ,i’. li 1; : ame .! :%d&Zi.

A That’s what .! t_h~.:ght you 3 ft‘ getting at.

(Laughter. B

MR. WISENBPRC: rs.il right .‘!Lt, of course, if

somebody had taken over ~GUT bcidy ‘RY probably wouldn’t

admit that anyway

THE wrrNJS%~ i i1i:.’ .\gents St ,,y‘ andh4ukierareoul

in those! green chaii.3. ?‘ii really c : worry.

MR. WSENBER!;. :;:kt.).‘ r l.bI(’ ,rd you’re going to

China tomorrow.

Are there a?:~ 9t!r-,: :~~_~estior!::

@40 response. :

MR. WISENBERC: I Lii ;x,,i- arc . :ilay the witness

be excused?

THE FOREPERSON: Yes, he MC : thank you very much

MR. WISENBERG: lk +-dly, I-. ig oew evidence,

hopefully we’ll net need io see yc ain.

THE WlTNE.SY. ghkl.’ Thar: *VU.

h4R. WSENBERG: I’iiank yol!

Page 83

1 THE WlTNESS: Thank you.

2 THE FOREPERSON: fiat& you.

3 (The witness was excused.)

4 (Whereupon, at 1:OO p.m., the taking of testimony

s in the presence of a full quorum of the Grand Jury was

6 concluded.)

7

**** *

Page 81 - ETage 83

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3337

points to make in affidavit

Your frost few paragraphs should be about yourself -- what you do

now, what you did at the White House and for how many years you

were there as a career person and as a political appointee.

YOU and Kathleen were friends. At around the time of herhusband’s

&a&h (the President has claimed it was after her husband died. Do

YOU really want to contradict him?), she came to you after she

allegedly came out of the oval and looked (however she looked), you

dont recall her exact words, but she claimed at the time (whatever ’

she claimed) and was very happy.

You did not see her go in or see her come out.

Talk about when you became out of touch with her and maybe why.

The next you heard of her was when a Newsweek reporter (I

wouldnt name him specifically) showed ’ up in your office saying she

was naming you as a someone who would corroborate that she was

sexually harassed. You spoke with her that evening, etc. and she

relayed to you a sequence of events that was very dissimilar from

what you remembered happening. As a result of your conversation

with her and.subsequent reports that showed she had tried to enlist

the help of someone else in her lie that the President sexually

harassed her, you now do not believe that what she claimed

happened really happened. You now find it completely plausible that

she herself smeared her lipstick, untucked her blouse, etc.

You never saw her go into the oval office, or come out of the oval

office.

. You have never observed the President behaving inappropriately

with anybody.
3338

You are not sure youve been clear about whose side you ’ re on. ’

(Kirby has been saying you should look neutral; better for credibility

but you arent neutral. Neutral makes you look like you ’ re on ’ the

other team since you are a political appointee)

Its important to you that ’ they think youre a team player, after all, ’

you are a political appointee. You believe that they think youre on ’

the other side because you wouldnt meet with them. ’

You want to meet with Bennett. You are upset about the comment he

made, but youll take the high road and do what ’ s in your best ’

interest.

December 18th, you were in a better position to attend an alI day or

half-day deposition, but now you are into JCOC mode. Your livelihood

is dependent on the success of this program. Therefore, you want to

provide an affidavit laying out all of the facts in lieu of a deposition.

You want Bennetts people to see your affidavit before it ’ s signed. ’

Your deposition should include enough information to satisfy their

questioning.

By the way, remember how I said there was someone else that I

knew about. Well, she turned out to be this huge liar. I found out

she left the WH because she was stalking the P or something like

that. Well, at least that gets me out of another scandal I know about.
time and was very happy.

I did not see her go in or see her come out.

Talk about when I became out of touch with her and maybe why.

The next time I heard of her was when a Newsweek reporter showed

up in my office saying she was naming me as a someone who would

corroborate that she was sexually harassed by the President. I spoke

with her that evening, etc. and she relayed to me a sequence of

events that was very dissimilar from what I remembered happening.

As a result of my conversation with her and subsequent reports that

showed she had tried to enlist the help of someone else in her lie

that the President sexually harassed her, I now do not believe that

what she claimed happened really happened. I now find it

completely plausible that she herself smeared her lipstick, untucked

her blouse, etc.

I never saw her go into the oval office, or come out of the oval office.

I have never observed the President behave inappropriately with

anybody.
3340
3341

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August 13,1998

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3342

II rc: Grand Jury Procadings

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Pages-Page8 I

DiversifiedRtoortingServiccs,Xnc.~202~296-2929 I
3343

Inre: GrandJPryProaxdhgs Mull

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Page 10

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6 A Wdl,kjtstwantaltoknowdidqofussay

7 attytbiqta,Ignesqupsctbaor~sk~didwe

8 snyan$hingmupsetkr. AndItoldhimattbattimtIwas

9 oabreak,Ibavenoideawktwassaid

!O Now,likImentioned,thiswasdmingtk

!1 wintmhqitwascoldoutthatday. lhnally,wrzda?t

IZdothis,but!4omthsweextaKlour~audand

13 penpkstam%gontkinsideaadti~ktso&imcsyou

14 cant&tktkcamOfsaanity~butatrbat~ ’

15 skwasbyberstlf.soIguestkykthucomeinandwait

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OntkiBsidc

Q Wbmyoulcfttogomyourbrc&wasskakady

hSi&tklAI&?

A No,sbcwasstilloutsidc. Wekveakusphmc,

whichislocatrdontkoutsideoftktraida,andIgucss

skwasgoinguptotklloLlsephonetousetllatasIwas

going tk otkr way.

Q Didyrmhearwhatanyoftkotkzoffuxrssaidto

!&r@sDtwilliamsaboutwhatkppalui?

A hastwixnIcamcbzktopmtaadka&duswhat

justkppami Attktim,BrianHallshikwasjust

smalllaufingwithba,youkDow,haw’sitgoisgor~

kwassayiqtokr. Mmstkvcupsctheramdsuppmllyslx

waltstamingoutand1guessskkeptcallingouttotk

wcstwiqgtospcakwithBeuycmica7xitbatwastkL

Q DidSagczmtWiisayanytlhgclsc?

A No. Igsssktalkcdtous,stiIltqiogto

gcttitkbcuanlofitaad_attkttime+myslIpavh

wboiSalso8bOVCKCithWilliams,wbidIwaS,csptain~

alsocaraetotkhi.lersndathattimeksaid,

vllabmjaakp~didn’thappal YoualllmhtaIld.’

we SE&& =Ye& sir.”

Amlkdidn’twantustoqeatitabaveity0ukmw,FalLingtootkroffhsaboutwhatjusthqqmc&

sounmidlmdcrsbod

Page 9 - Page 12
August 13,1998 I

Inre: GrandJuryPqeedhgs MIlli

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Q Whetdidyouhm?

A Wcll,attbfittim,SageantK&hWii,kgot

calkdtoBcnycurrics~andzmmwhat~~takf ’

tkyaaidkwasiaBdtyCu&‘toffimdtkl4uii

caux8ndshuttkdcmkhindhimaQdwnrmitobmwwkat

tktimwasoutattkwthwtgateandkwasupset,f

~,~~ofB~~~~~B~~~

~~~~tk~~~a~~~~

izwidc.

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klmw,xMllta&orwkevu*mdtktwastkt Aadtkt’r

8ttktimctbntkcaIIKoatRJuamldwantimfindaut

wktjustkppalaiouttlmc Andlilnt’sauIxumnbu.

Q Now,yousaidtktymkdgoncmbmkandabcmt

tnminurcsaftuthatyauwemcalkdbackmyour~

A Itwasprobablylikc10toI5mhukshta. I

ramm~gohgdown,gmbbingmyfood,ataaandwi&audat

lkttimt,wff.impoaer,lnpoadbacktatk~

ga*AsAp.” Andtkt’swhIwmscalkFdbac~

Q Awlwimyougotbwktotkwtthmstgak,was

SagcantWillhwtknwaithrgfocyouordidkamiw

afetkt7 Ifynum!nmbu.

A IhowwkzcIwnsmbqk,Iwasvayckmtomy

post,roitdidthtahc~ytimctOgdbadrtOpost+ir~

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cuulda’tthinkattkttimewkt~~

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kpptZd-IwaSOtt~

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mcamtsedStX@BltWilliamsbtCkrr;tyap-gtitC

potqffvmwktkmid,wktsageantwilliamssaid,did

)mualncl~tktsagrantwilliantskd~spdantn

wtyctzfricsadtbtResidEllt7

A Yes.

Q okay And~tWi&tmsmaidtbingsthatkd

ycmtobGLiEvttktkhadspokmtotkRcsi&at

my*

A Ye?+.

Q AmdIthhkyottsaidtktmmcmc shuttktbw

A Suppaacdty,wimtkheus,whibkwast.Aking

toBdtycMitinkroftia,kcarmtinxbae.

Q Ldm:justiMmuptyau bhissageapt

WilliarnsspmkiqtoyasdiraSlyatotkpmp?

A ~sqpeaLingtotka~titc&mup. ‘

Q O~JW. Attd~~~'tekarimtbisdittd~ftum I

I

Page 13 - Page 14

Diversified Remtim Servi~. Inc, (2021296-2929
3345

1 ScrgceatWilliams? 1

2 A Yes 2

3 Q Wktdidksay? 3

4 A IhatwhatmrWaSSaidattbe- ‘ gate-. 4

5 Bcttycurric. Hcgotalkdtokr0ff1cetotalkmbrrand 5

6 suppoacdlytkPedcatcamcintotbcofficcupsct~ 6

7 whatwassaidattknorthweStgatc. 7

8 Q Anddidhtsaywktkranyanestuttthedoor? 1 8

9 thoqghtyoumentiimedamia*agotbatthedoawas&ut. 9

1 0 A Yes. Tbtprcsidcntsupposadlycamcintotkoffirc 0

1 1 andslmtthcdocrwi&kwasintkofficc. 1

I2 Q Anddid%gcantwillirrmssaywbatthe- 2

13 badsaid? 3

1 4 A htt.btbtwantedtOkWWWhtwaSSIidattk 4

1 5 northwcstgatcarwhatofFicersaidsom&iqattk 5

1 6 northwcStgatc. GkcIs&Ih3vcnoidca~wasssid’ 6

1 7 brxau!xIwasr’ttbae,youknow, wkaeverth&u&alkiq 7

1 8 toMonica 8

19 Andkjustwantedtoknowwhowasoutatthc 9

20 northwestgateatthattimcbezausesuppasaiLyoffimBrian 0

2 1 HaU,IkkvekwasdoiqmstoftktahgwithManicq 1

22 knmthavcsaidsoWhingtbatupettheFrai&atandia 2

23 tmnkwan~toknowwhowaspostedattkxwhvcstgntc 3

24 attbattins. 4

25 Q Did Sergeant Wiiams convey what tk presideat’s 5

,

,

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spQkctohim7

A Allksaidtouswasthatkwasjustupsct

Q DidScqgmntW%mssayaqRhiqg&utaoybody

bcingfiralcrbciagdisciplinlxlabsiogtkirjoba

qtbinglikethatovztbis?

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~wlwcvusaidit. AndkraidktalMtoBettyclarit

andcxplainaltohathutkwas~doiqti~and1

gucssBc%ty~mustkvctalMtotkR&hSujust

&krmlkalwithlceithWluieiqjusttbmctwq8DdKeitb

winiamsandcapbGlRlnkcamcupandtalkzltour,said

thcytalkaltoBdtycwic,*cxplairredt0hrrtktyoU

wucjustdoiDgyourjobMdhomthisp0intm,wktcvcr

justkppala$didn’thappm.

Q Now,wka~tWillimuwrrrccotmtingwbnt

bqpcnalwkakspoktcithcResi&a~umsC+ainPurrk

pxeserlt7 Ifyollzunanbu.

A Wknkwasmlkjngtotkentircgraup?

I’msoq. Ycs,kwas. fbr&vek~prerPent

Q Okay. DidCaptainPurdicevasaytbatbc,CaptCn

PurdiLkdspdrmpaSol@ytotbcPKsiden17

A Hcdidn’tsaytlmtkpsRonaltyspokctotk

Pmida&but~ttbetimcwhenKeithWiGmswascalkdto

JMyCurSsofficqkknew&atUncwasapmb~ro

I

Inrc: Gmdhrry~ August 13,1998

,

Page 1’

kintumcallcdhis sllpmbr,whichwascaptainprrrdic,

tobliqgbimdowatoBeqrcul+soffrcttolcthimrnow

~j~happcncd

Q Toyourknowlcdgc,bascdonanythiqthatyoukard

orknowyounclf,doyouknowwkthertkPnxi~tevcr

spoktocapcainPurdiethatday?

A No, not to my knowledge.

Q Andyousaidcariicrthat~ptain&dicalso

addrtssedthtgrwp?

A Yes.

Q Andksaidwcudstothttffectofthisdidn’t

happen?

A Yes. Heaskeduswhatjusthappcncddidn’thappcn,

mcrrrrirrgifWlCftpOStgOklgtOandbaOff~~-

clse,youknow,kdidn’twantustorepeatit. SoQ IfyouA Hcdidn’twantusqcatingitanymorc.

Q Iset. Hcdidn’twanttkstotysprcadaround.

A No.

Q ~k=yaaythingbcyand~justhqp=d

didn’thappen? Didkcxpiainwhatkmcantbythat?

A JusttomyknowMgcfromupsettingBdiyCanic

mdtkResickn~kjust~‘twantusqcatingqthing

tbatjusthappcnedaadkjustsaidyoumxhstmdsadnn

saidyqsir.

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kdisciplina.lorfnedcrallythin8likctllat7

A AsfaruKcithWilliamcorthccaptain?

QMm-hmm.

A No,tbeydidn’trayqthing,tomykmw~

rboutanyoncbcingfiral. JusttkonlythidgIxcmanbuwc~

KicitbWilliamssaidtbattkResidentwasupactuxlk

wantcdthntpcrsoogoD&wkcvusaidwhflomrtbcysaidtcl

Ma&a.

Q WasitcvQconvqrdtoyoutbattkwbDJtthing

kdbaJlsmoo&dovuinsaneway7

2 A Yes.

3 Q okay. AndthatwasbySagarntWiUimna?

4 A Yep.

5 Q Andtkt’rwknkmidtkt-you&de&u

6 youdida’tlowm~thtxlkppa&whetha~aPrithtad

7 spdcalto~. DoyDukvcMyideahowitgatsnwtkd

8 ovcr,basalonwhatyoulrard?

9 A JustqpoedlyIC&hWiUiamsandBcttyCu&

0 talkai,asfarasIlaKlw. Wbultthcysaid1dm’tkmw*btlt

1 Ijustknowtkytalkcdbcachothcc.

2 Q Okay. Didyxtuevcrkarnbouttkiacidmtagaia

3 *that? Af%ertbatc0xl~tiontbatyouwm;rpmtof

4 withcaptainRKdiEandsa8cantwilliamJ,&tbcissptcw

5 calEup&lIfh.tbat7

9

Diversified RemMim Services, Inc. 0021296-2929

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hire: GrandJumProwdnm Mu&i-P8gP

I Page 21

1 A No. Tbosttwo-tkxtwoncmunncpptom:and

2 ukulmcmnyotlmqumions. Itwa8ju5tafwwaythg

3 wascNu,jnsts8idrous,yaukaow~youkvctokl?azefd

4 wktyaumytol!JaJphcwfmtkycrmeupbaebvi&

5just-youkmw,ifalyoas-Immqulywds~~

6 askyouifshcRai&ntrathmre.Imcan,~~uwcr ’

7 ~~~~~~~~~~~

8w&iogaaallc*laiorpost

9 Ms.WIRTHz okay. officcx,wcrcgoiugto~you ’

0 tonpoutfarafcwmin~.

1 THEwrrNES: OkSy.

2 (wiiarspgd WitnmsKc!dkd.)

3 THEpOREPERSONz OfE&rPae,I’dliktoxuuhd

4 youtktycm’rc#munduo&

5 THEWrrNES: Yox.

6 BY MS. WlRTH:

7 Q OfTicstbt gmndjummlmd~f&wquchnsfor

B yF3u. -nlcfimmir&dyoulwukveailyCxwmfsa~

9 widloff%zHallarofFlwNpdmicckafiuthisd$s

3 tbEtyDuvcdizscriiuadaha,yaultuow*thetalkrbstp ’

I bltdwith~twiniamsandcapbninPufdic? Didynlcw

2h-Ycocwlmb~yourpdfwithHanorNicdnviecb:

3 sbouftbcinci&s?

4 A Ya. Ahcrtbcf~wet&ai.

5 Q =ya;l-wbatyout&alabout7

p-22

I A JuststUtryiqtofrndoutwhatkp~from

2 OfFi~HalL &saidkiwitedkrtacemciubecwscit

3 wascoIdoutsidcandIgucsskmusthavcmmtioncd-small

4 talktok.r,yOulcixnv,Bct@csm%maynotkavailable,

5 sk’seitkr@ingatouroreitbrtalkhgtuElhbe&

6 Mondale.

7 Q l%~~~&ndaSe?

8 A Imscwry,&zmorhhndah. ’ Andfnmntkttinq

9 Iguc!sstbfztswhcaskgotupsct8tMiGitkr-cennedwt, ’

D Iklicwksaid I’mnotsutcifskstandwtoftk

1 mikatKlmltbadctoapayplKmcorsaarrRhia&~

2 outtotbcwcstwing

3 Q okay. ~~~~~~~-~d

I yuutalktocwiccrNii? Doyou IenExlberthatat

5 all?

6 A IknowItaikcdtohim,butIdontmnmbcrwhat ’

7 ksaid ~tftprhib~ysauebhgtksam.

B Q HavcyoueMheuianysubsq~tcrnrMsationswith

9 capt&Plndieabouttllis?

3 A No,justtktdtxywknkcameuptousandsaid,

t ~~,~j~~~~~‘t~ Imcqasfar

2 asdouQtkrO@lKitihgelscwas~ti~~tktwc

3 ofus.

0 Q WbataboutSagamtWi? Havcyoucvuxkd

5 rmy!zukmq~t~~~withhimabolltthis?

August 13,¶998 1

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1 tllisw8stksmnctbmtktwalmppo!w@aubcdaad I

2 mcsa,Ijtmknowkpidkcrmtinmdsbut&e&xxb&ind

3 him. IQa’tknmiftkaewas~craCkzddoororaat

4 Q ohy, DidycmlcvcrknrScqcmtWiUimsnuhoa

5 ruackcddoot,toycmrlnl!mo@

6 A Natmmytmmry.

7 Q Okq. DoyuuhwcanyknuwkdgcesQwbztkr

8 Malicalmviey~didIgtiamtkwatwiqgttmtday7

9 A Tozny~Idm’t&inksk~htkt~.

10 fmQn,u~asIknow.

1 1 Q Yaooovumwkrqtnintktday7

1 2 A No.Iaewm~Inqgutintktday.

1 3 MSWlRTEIZ hybO&&?

1 4 (No mrpmre.1

1 5 h.Is.WIRm olmy. W~yaplmneoll1 6 THEFDREPERSON: Yauwacuwd Tbmkyarwzy

1 7muclL

1 8 MS.WIRm nm&yaqoffiw.

1’9 THEWlmEss: AllI@. Tbmkym.

210 Ms.WIRm nmkyou

21 cfbewhasmracwed~

12

2.

3

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2 (Wkmpm+8tll:19rm,tbctBkiq5ot~

3 iDtkplt!wCeofa~qamlalaftkcilmbdhuy~

4 ixncludcd.)

5 **Cob

Page 21.0 Page 24

Divmified Rcportinn Services, Inc. (202) 296-2929
3347

OFFICE OF THE INDEPENDENT COUNSEL

05/26/98

Date of transcription

JEFFREY J. PURDIE, Captain, United States Secret

Service (USSS), Uniformed Division (UD), date of birth June 19,

1960, was interviewed at the Office of the Independent Counsel

(OIC), 1001 Pennslyvania Avenue, NW, Washington, D.C. 20004.

Present for the interview were Associate Independent Counsel

(AIC) MICHAEL TRAVERS and AIC MARY ANNE WIRTH and Department of

Justice (DOJ) attorneys DAVID ANDERSON and ANNE WEISMAN. PURDIE

was interviewed under the terms of an agreement reached between

the OIC and the DOJ. After being apprised of the identity of the

interviewers, PURDIE provided the following:

PURDIE has been employed by the USSS since January of

1982, when he entered service in the UD. In June of 1986, having

been promoted to Sergeant, PURDIE began working at the White

House complex. In September of 1989, PURDIE was promoted to

Lieutenant, and in January of 1997 he was promoted to Captain.

PURDIE became one of eight USSS captains who are Watch Commanders

at the White House. From January of 1998 until present, PURDIE

has served as the Branch Administrative Captain of the White

House.

PURDIE recalled an incident that occurred on a Saturday

in December of 1997. PURDIE could not recall the exact date.

Sometime between 11:OO a.m. and noon, PURDIE received a

telephone call from Sergeant KEITH WILLIAMS. WILLIAMS asked

PURDIE to.respond.to the Northwest gate of the White House to

address a problem that had arisen. PURDIE respon$ed and met

WILLIAMS on West Executive Avenue. WILLIAMS told PURDIE that

MONICA LEWINSKY had come to the Northwest gate to make an

appointment with BETTY CURRIE; LEWINSKY had packages with her,

but had not been cleared in through WAVES. (PURDIE knew LEWINSKY

by sight and to say hello, as they both had worked in the East

Wing of the White House for a period of time.) WILLIAMS advised

PURDIE that the gate officers had told LEWINSKY to use the house

telephone to call CURRIE and make the appointment. LEWINSKY did

this, and came back in the gate house and told Officer BRYAN HALL

that no one was in. LEWINSKY then left the gate house. WILLIAMS

told PURDIE that WILLIAMS had received a telephone call from West

Wing Lobby Officer BRENT CHINERY. CHINERY told WILLIAMS that

05/21/98 WASHINGTON, D.C . 29D-OIC--LR-35063

File #

05/26/98-.

Date daated
3348

23D-OIC-LR-35063

JEFFREY J. PURDIE 05/21/98 2

Continuatton a’ OIC-302 ol . On . Page

CURRIE had spoken with him. CURRIE was upset that the gate

officer had told LEWINSKY the location of the President in the

White House, and who the President was with.

WILLIAMS told PURDIE that he had gone to speak with

CURRIE, and that CURRIE was upset. CURRIE told WILLIAMS that

LEWINSKY had left the White House complex, and that she had

called CURRIE several times to make an appointment. CURRIE was

concerned that one of the Norhtwest gate officers had told

LEWINSKY the President's position in the White House, and who the

President was with.

PURDIE went into the Northwest gate house to speak with

the officers posted there. PURDIE recalls telling the officers

not to worry, that they would take care of the problem. PURDIE

and WILLIAMS then went to the West Wing of the White House to

speak with CURRIE. When they arrived, CURRIE was with White

House photographer BOB MCNEILLY. MCNEILLY left the office.

CURRIE got up, closed the office door behind PURDIE and WILLIAMS,

and asked them to sit down. CURRIE was clearly upset. CURRIE

told them that LEWINSKY had called from a pay phone to make an

appointment to get into the White House. CURRIE told them that

the gate officer had told LEWINSKY that the President was with.

ELEANOR MONDALE in the Oval Office. PURDIE advised that someone'

suggested that LEWINSKY may have seen MONDALE enter'the White

House, had come to her own conclusion, and then told CURRIE that

the gate officer had disclosed that information. PURDIE could

not recall who brought up this scenario.

this explanation placated CURRIE.

According to PURDIE,

CWIE told P?JRDIE and

WILLIAMS to talk to the officers and find out what happened_

CURRIE also told them to keep this incident quiet. PURDI E

apologized to CURRIE.

PURDIE then went to speak with the officers. at the

Northwest gate. PURDIE spoke with Officer HALL, Officer GARY

NIEDZIEWSKI, and perhaps one other officer. PURDIE told the

officers that everything was all right, and no one would be

disciplined. PURDIE stated that either on this occasion, or on

the first visit-with the gate officers, PURDIE asked HALL what he

said to LEWINSKY. PURDIE is not sure what HALL told him.

PURDIE met with CURRIE in her office a second time, and

told her that he had spoken to the officers. PURDIE told CURRIE

that if they gave out any information it would not happen- again.

PURDIE asked CURRIE if she wanted him to do anything else. CURRIE

replied no, but that she wanted to keep things quiet. PURDIE
3349

OIC-~O?;~ (Rev. 8-19-94)

29D-OIC-LR-35063

JEFFREY J. PURDIE 05/21/98 3

Contmuarion of OK-302 of

agreed and left the office.

.On . Page -

PURDIE spoke with CHINERY in the West Wing lobby and

asked him to keep the incident quiet.

PURDIE advised that he spoke to WILLIAMS again that

day. WILLIAMS approached PURDIE and asked PURDIE if he had

spoken with the President. PURDIE refused;to answer any other

questions regarding this, invoking the Protective Function

Privilege.

PURDIE stated that on the same day he telephoned White

House Operations Deputy Chief CHARLES O'MALLEY, to explain what

had happened. PURDIE told O'MALLEY that CURRIE was satisfied and

that there should not be a complaint. O'MALLEY thanked PURDIE

for the call.

PURDIE advised that about 45 minutes later he received

a telephone call from the Presidential Protection Detail (PPD)

operations desk. The PPD agent asked if PURDIE had a problem

with BETTY CURRIE. PURDIE replied that he did not. The PPD

officer then asked PURDIE if a PPD agent had been involved, to

which PURDIE responded in the negative.

A few days later PURDIE spoke with Deputy Chief

O'MALLEY. PURDIE asked O'MALLEY if he should follow up the

incident with a formal report. O'MALLEY said that that was not.

necessary, as he had not heard anything further,

PURDIE recalled, at some point, he spoke with FREMON

MYLES about LEWINSKY. MYLES stated that he was pleased that

LEWINSKY was gone from the White House.. PURDIE advised that he

did not know why MYLES was pleased, or how he responded to MYLES'

statement.
3350
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UUITCD STATES DISfRXcT COURT

TO,4 TKC DISTRICT OF COLUWBXA

GMYD JURY -CCDI”CS I

en Dmeemkar 5, 1997. e-neinq .t 4:27 p..., beface:

RfS.CllT J. DITTKNN

SoIauu *ILc~

JacRIC M. DC-, JR.

nRed%andJuryProcctdings Multi-Page” , Frihy, July 17,1998

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PROCEEDING S

-upa

JEFFREY JAMES PURDIE

wascalledasawitncssand,afterhavingbeenfvstduly

sworn by tk Foxperson of the Grand Jury, was examined ant

t&fled as follows:

Q Tell us your full name, please?

A Jeffrey James Purdie.

Q Where do you worlc?

A United States Secret Service uniformed division at

EXAMINATION

BY MR. PAGE:

the White House.

Q I want to talk with you about Saturday, Dexxmber

6th.

A Ye&sir.

Q All right? 1997. Do you recall that day?

A Ye&sir.

Q Inhere was an incident outside the White House that

day, correct?

A Yes, sir.

Q As a result of that incident, you had conversations

with the President. correct?

A Yes, sir.

Q Would you tell the grand jury what those

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conversations were?

A Give specif& or how do YOU want me to lead inio

this or --

Q If you recollect at this time the substance of the

conversation that you had with the President. we’d Iiks 10

start with that.

A lcansfartwiththat. AtthetimcIwasinBetty

Cur&s office. I was engaged in a conversation with Bew

Curric in reference to an incident that occd at the

north- gate.

SometimeduringthatincidentthedoortotkOval

oflice opened up. The President walked into Mrs. Curric’s

office or -let me retlact. He kind of stood in the doorway

thex Mrs. Currie introduced me as Captain Purdie,

some&inginrefexna tokingin&argeoftheWhiteHoUP:

atthattinlc.

?hc President acknowledged me and Mrs. Currie made

a statement something to the effect that the situation had

beenhandledandksaid,7hankyou. IhopeIcancounton

your disuetio%L”

Q Hesaidtbattoyou? “IhopcIcancountonyour

discretion”?

A Something to that effect, but the word discretion

wasused.

Q That was the message that the President sent to

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you?

A bs,sir.

Q Wasklookingatyouattktiux?

A ~coukintsay~00pacenthokiqatme. ’ &Was

eitherlookingatmeorinmydirection,someth@.

Q Didh4rs_Curriehearthat,toyourknowledge?

A To my understanding, I don’t know how sk couldnt’

have heard it.

Q

that?

A

Q

A

Q

time?

A

Q

And how near wac you to the President when k said

Ten to fifteen feet.

Anybody else present when k said that?

No, sir.

Any othu conversation with the President at that

No, sir.

Tell us how and describe for tbc members oftk _

grand jury tk P&dent’s manner or how k was acting at the

time.

A I’m not sure if I really understand that. If

you’re. asking mc if there was anything unusual, the way his

mannuisms were, 1 would say no.

Q Well, when k came out, did he open the door in a

hurry or in an angry fashion?

A No,sir. Itscemcdlikethedoorwasopenedina

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normal manner.

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Q What about the tone of his voice?

A Business tone, normal speaking tone.

Q Did you reply back anything in response to “I hope

I can count on your discretion”?

A It was something to that effect that he said to me,

but the word discretion was used. I believe I said something

to the effect of “Yes, sir.” I mean, I’m sure I said “Yes,”

or sometbiog, “Yes, sir,” to that effect.

And did he acknowkdge when you said “Yes, sir”?

I don’t believe there was a verbal acknowledgment.

Was he still looking at you?

I believe so. Yes.

Any other conversation?

No, sir.

BettyCurrieistberetbeentiretimeastbis

exchange occurred?

A Yes, sir. At the time prior to this occurmnm,

she was sitting at her desk I was sitting on the opposite

side of her desk. And as the door opened up, I of course

realized who it was, I stood up.

Q How did you understand this request by the

President to exercise discretion?

A It was my understanding at tbe time that tbe

situation had been handled, meaning there was - I’m sure

Page 6

1 you’re aware that there was an incident at the northwest gate

2 andthatrhadtaken--whatI’mtryingtosayisthe

3 situation was taken cam of.

4 Q But how did you understand that request to exercise

5 discretion, that you should say nothing, that you should say

6 a little, that you should say a lot or what?

7 A Attbattime,itwasmyunderstandingthatIwasn’t

8 going to say anything.

9 Q ‘Ibat’sbowyoutookitthat&y,attbattime.

0 A Yes,si.r.

1 BY MR. BI?TMAN:

2 Q ‘Ibat’s why you responded *Yes* to tbc Pm&lent’s

3 question? Isthat correct?

4 A Yes,sir.

5 MR. BITTMAN: That’s all we have for you right now

6 Captain. ‘Ibegmndjuryhasfiishedtbeirbusinessfor

7 today. We will recall you next v&t. Thank you.

8 MR. WISENBERG: -Ibank you

9 May the witness be excused?

0 THE FOREPERSON: Yes. Hiank you.

1 (Thewbesswasexcusd.)

2 (Whereupon, at 4:38 pm., tbe taking of testimony

3 in tbe presence of a full quorum of the Grand Jury was

4 concluded.)

< *****

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3353

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PROCEEDING S

JEFFREY JAMES PURDIE

w8scalkd8sr~8rld.~bBvingbcQfm1~

swornbythcihpmaioftbcGmdJury~msarmioodurd

trtifii as follows:

E?MMNATJON

MR.WISEBlBERG: MadamFaxpam,~bmvcaquarrrn

THE FOREmSGNz Yer. me Q.

MRWBENBERG: AietkYeuryuMutlaomalpauwu

in tk_gmd jury mm?

TH.EpoREpERsoN: -nlaa2cl5aE.

MRWISENBERG: Tbmkyou

BY MR. WlBNBERG:

couldyalstatc~oamcfortbcrecanlpleue?

JcfficyJIIllerPurdic.

AtUih0W&iyWrspellhtdk?

P-U-l--d+=

AndcanyougivcusyatKtitkpkS?

i’lll~C8ptSiDitltbCUtitCdSi8tCSSCCZtSCl”Vk

uaifcmncddi~uri8na.ltotkwhittHouotbrrach.

Q AIlrigk Andsoitwmuidbcapptuprimtordar

toyoufaustDrdcrtoyauu~ptainPuaeca=tl

A Yes, sir. If that’s what you want.

Q 0kay. Lumtjustbcfcmwcstartsaytbatmyname

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IS

isSo1WisahagandIm8ttomeywitbth:OfficGof ’

lrl&mdmtCauruef. Tomykftiskryhnewi53bnnddlc

aalsoanaaomcyforthcmiofIndcprrdentCouard.

msistbcgKindjuJycourtmporI%thcst~tbchiics

and~tkmrnoftkgmndjuty.

TbisgmndjuryisafedaaIgmfdjwythtw8s

impar&dbysUniwdSmcsdistiictcourtj&ebsci

tbc District of czohmbi invcstig8~ anmgotkf tbh+

WbCkOerraiop7SClIU cdnnmiucd fakalfclmk%s in

comaximwithahwuitknownasJoncsv.Clintom. Do

you undcrrrrad’l

A Yes. sir.

Q /&Bright. N~~,bcfmwegusmricd.Iwwm

bri&ypovcryow~mdmpmsibilitksuagnnd

jwywitnm. Piiofe4yaudm+thvcrri@toimvc

8nmomyintbcctlummm intkgnndjutyroalLwitli

yw.butyeucmtbavethatnftDnyoutsidefarcmmMaa.

A Ycs,sir. .

Q Doyouunckmandtbnt?

A Ya, sir.

Q Anddoyouhavesucbanattomcy?

A Na sir.

Q Oltsy. YOU’IC here without UI a~ m&y7

A Yes. WcUidobavcrcprcmmiombyt&Sead

savicc.

Diversified Rtmmting Sticcs, Inc. (202) 296-2929

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In a: Grand luzy proc&dings MIlli

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Page6

A Yes. sir.

MR. WISENFZRG: AH right. With tbt, I will hm

you over to Ms. Wirth for qutstioning.

BY MS. WIRTH:

Q captain PIEdi% you have bazn anployed by the

Secret Service sina Jsmuary 1982?

A Yes,ma’am.

Q And you% in the uniformed division?

A Ycs,ma*m.

Q And in June of 1986, you \nnrr promoted m sergeant?

A Yes, ma’am. 1 bclicvc that’s -1.

Q And you began working in the White HOUSE complex II!

that time?

A AsImoffkr,&rImntthrou&basichning,

waswbmIfm~ass&naltotbeWhitcHouscmdtbiml

rotat&outtoourForcignhGssionsBmnch Iwasprmmtcd

in 1986,1bclievcitwas 19~7~I~t~~~~

House,in June.

Q All right. And in 1989, you whrt prcmmted to

licutmant. ls that cmlTc4zd

A Yts,ma’am.

Q And in 1997, you wcm prumoted to Captain. Is that

camxt?

A No, ma’am I bdicve it was 1995.

Q Okay. Andwbmdoyau~?

hdy 23,198

P-7

1 A My-t assigmmt is Im’ tbc administrative

2 captain a tk Wbitc HOUS bmnch.

3 Q Okay. ~~~~~~~d~~~?

4 A EbdofJanumy~bq+m@berraiagfF&mazywknI

5 Offlcialiy took over this position.

6 Q And that’s 1998?

7 A %s,ma’a;m.

8 Q h &rumba of 1997, wbat was yap position?

9 A Iwasawatchcommmdu at the Wlh House.

0 Q Okay. Andwbtdocsawauhaxmmn&rdo? Wba

1 doestbatmerm?

2 A A-comma&r isindrargc:oftllemifomcd

3 day-todayopaxuionsattkWhi~HouE.

4 Q Okay. DoyourccaUanincidca~tbatocamed

5 inaaiylkcanbat997atthcnorthmagarc?

6 A ub7 Q hwolviqj Monica Iminsky.

8 A ~yrm~dingwas~unc. Imcari-cxcusmc.

9 I)eccmk?. It was%% early -

0 Q WhatdidIsay? Imsorry. ’ ’

1 A Ithughtyoutidearly. Imaykmistakar. ’

2 I’mlxzvous

3 Q hxmbcr. Tbat’saUright. Iamldbc,too.

4 Aainci&BttbathappcaedinDcccln~d1997.

5 A Ycs,ma’am.

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AttbDclnhvmtg8e.

Yes. mamr. ’

YalkmwwhBtI’mmlking&out7

Yes. Dltlaal. ’ I do.

Adyatwucaathltyanltrby?

Yes. ItlaatL ’

what wyorrr fPst involvamJt wilh th: incideat?

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1 halfway.

2 Q Didyouqeaktohim?

3 A Yes,maan’

4 Q Wktdidkttllyou?

5 A Hcuplaincdalboutasituati~that~at

6 tknorthwestgateinref-toapeaxontr$ngtogU

7 ~totkgatqwyix!gtamakezfaappointmentti~tk

8 Prcsidmt. ~t~~~y~~~ap~~~a

9 CooyQsBtiQII

0 Appamdy, Qy: of tk off- calledmt

1 willi8msafultbisizIcidartoarrrr#t. fi&zgaawii

2 tkawabt85dhadaum~ withMS.Bcqcurrk.

3 Q DoyouknuwBettycIprie?

4 A Notpcraondly. Iknowwboskis.

S Q Didyoukarwkt-didSc.qsmtW~tiyou

6 wkt&try&miCtoidhim?

7 A Yc&ma’atn

a Q Wktdidktellyou?

9 A !bge,antW~toldmebasicallytbattkpuson

o ~~~t~~~~~H~~~‘t~~~

1 tkaorthwestgatc,mackscvaalplwnecall.sframajxiypboae

2 to~Cunie’soffice,rriedu,gctc~~togetan

3 appointment with tk Pr&leIlt or hfrs. Currie. which of

4 ~~~~~t~li~~~~_~‘s

S Off-lee. sergeant wiiliams also wrnt on to explain that tk

Page 10

1 Resident was ups&

2 Q Did Sergeant Williams tell you how k knew that tk

3 President was upstr?

4 A Hewentontosaythatkgotthatfrom

5 Mrs. currie.

6 Q Okay. So IMty Currie told him that?

7 A YCS,XW~Z~IIL ‘

8 Q Did Sergeant Williams tell you wktkr Betty C&e

9 was upset?

0 A Yes, he did. h&!L fhniC Was dS0 UpSCt.

1 Q Okay. Did mt Williams tell you wktkr k

2 himself had spoken to tk Rtsidcnt?

3 A Atthattim;w.

4 Q AU right. What happated next?

5 A Healsoc~rplainedtomcthattkoff~cers,

6 particularly one offica; Offhr Brian Hall. was cxtrcmcly

7 up@ worried about losing his job.

8 Q Didk~U~~~

9 A Becawz apparently there w&s an accusation king

0 madetowardsOffiarHallattktimethatkhadgivcout

I the President’s location and who tk Resident was in with

2 an appointment at tk time.

3 Q And wbwthat accusatiti coming from?.

4 A him. Ctie.

5 Q Now, did Seqeant Williams tell you wktkr k had

-PflgP July 23,19!48

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1 A Yes,m!iam. ’

2 Q Allright. Whatkppcnedthm?

3 A ~tw~~~~~t~~.~S‘

4 OffIce.

5 Q Okay. Andwhodidyousettbse?

6 A AswearrivadintoMrs.Chie’saffrce,Ralp~a

7 ~~H~p~~~p~~~~~~~~

8 inkroffi.

9 Q AtxhvhathapparedtoRalph?

80 A ~Spoh!witbhim ~twily,ksoondqwxcd

~1 Oucck&par@Mrs.0xrieclosultkdoorandbad

12 Scrgcant Williams and myself take a scat.

I3 Q ?&:photognrrpbartktyouopdceto,didkEpcslrw

14 youaboutthisincidcntatalI?

IS A No.

16 Q IicbasicaUy cOq#hMdfortk~?

If A Yes,ma’am. BccarrPeIbadn’tambiminawbile.

#8 Q Allright. Af&rtkpbotogqkrut,wkt

9 bappentd?

!O A hbs.Cuniesatusdown.

!I Q Wastkdoorshut?

!2 A kS,miam. ’ ny:chxwasShut

!3 Q~Didsksluttit? : --.

!4 A Ye!+. shtshuttkcboroncetkpboto@apkrlek

5 ScrgamtWilliamsandmysclfsatdowaandI’mnotsureti
3356

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I cxady initiated the ccmversation, but, of come, the

2 conversation was in reference to this problem.

3 Q &cus M. %krc’ YOU in bl)’ bTiCS’ Offk a t

4 astpOinl?

5 A Yes,maam. ’

6 Q Andyoukm!what&aycunicSoff~CCwaS? ’

7 Yourt’ famihrwith WhaE it was?

8 A Yes,mhtn.

9 Q tkay. Andwne)OUabiCtOStetbcdoorOftfr ‘

0 ~~~~~~~~?

1 A whatdOOrtOtbChdoffice?

2 Q Does Mrs. Cmie’s off~ta, is it anywberc ogm a

3 doorthatlcadstotheovaloffice?

4 A Ycs,nd8m.

S Q Anddidyoulookatthatdm?

6 A Ys,ma’am.

7 Q %‘asitopcaorchmd?

8 A ThtdoorwaS&=d.

9 Q firi@_ So you’re in h&s. CU!+‘s office with

0 Sugcant Williams. what happmcd?

1 A We briefly wtthfou& the synopsis of the tymu

2 &atbappalcdatthcnorthwcstgate. Bcttycurricwaltonto

3 sayhowupsrtshtwar.at~thappcntdandshcalsostatcd

4 thattkResi&ntwasvezyupset.

5 Q Okay. Did she say why the Prcsidmt was upset?’

Page 14

1 * A Appamtiy. again. tk accusation was made that

2 OfficcrHalLandIdontk3icvcMrs.Curriccuc!?kdtk ’

3 offis’ nauc but was upset that me of tk offaars. of

4 course king Offhr HalL gave out tk informstion aboul

5 fk Midart’s location and v&n his appoinancat was witb.

6 Q Okay. And did &ny Cur+ ?cU you anything that

7 tbc Resident had said about this?

8 A f&%tyCtiwaHontosaytkhcsidartwasvay

9 upset about it.

0 Q What wes &tty Currks’ dmrcanor at thet point!

1 Wbatdidsksumlikc?

2 A BatyCunicasfuasbuduncmor.obviouslyia

3 ~~~~~~~but~~‘t~~~~~

4 assq!antwilliamsbadaiginr4r~ihaubeiag.

S Q Okay. Howbadk&scriihcrrsbdngto~

6 with?

7 A -up*

8 Q AIlright DidF.WtyCurrictUyoubmvsk

9 ur#ottbcRsidentfoundoutaboutwbathadboatsaidrt

0 tkllo&wcslgate?

I A Yes.maam. ’

2 Q Wba~didsktellyou?

3 A Skacphtithetattt&poh~Ikkvcrk

4 usaih4onicaLcwbky’smmcfatkfinttixwsknpiahai

5 tbmtMoaicahwinskyap~tiytilogUiaforur

P8gP hrly 23.1998

Page15

f app4etlnatt. ofcot#lr!z_ tk Offleers ckkcd throw the

2 computer, Im ’ sufz youd’ awax that tky have a cumputcr

3 system for ckcking for appointxmts. She wasn’t &2rcd i

4 for an appoilmmt.

S mofflclrdi,m%dbcrtork~phoncwtrich

6 isoutsidctbcbox. SkattcmptaitocallBatyCmic’s

7 off~~~~~~~ph~~~~~y

8 couldn’tgdtbmugb.

9 After a few minutes of cmvcrsation with the

10 off~-~l’~~t~~y~~~~~~

II occumIoutsidctbepostorinsidcthcpanwithofFi~

12 Hall-sbe&pamd,wmttoaphoneboothsomcwbmintbe

13 v~i~~of~~~~~~~~~~ff~~

14 mcInptsbgetthrougbtoBcttyCunic.

1s onatkast5nec8ccasi~shcgotthruughtoBcpy

16 ~andskwastma+dovmmaaqpohmmtby&tty

If cmic.

i8 Q Andsbewaswhat?

.9 A SkwastumdQwa Bctty:Curricdidnotrnban

!O appoixltmalt for her on hat day.

!I Q Ihst’swba!BcttyCmicto~dyou?

!2 A Yes,maan~ ’

!3 Q Andrbatwhathappmcd?

!4 A whatkdtotkphacca&wkfc~eadedupgoiqg

!S uptotbcriorthwsgate. ’

Diversified Report& Services, Inc. ~202~296-2929

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1 Q DidBcttyCurrietcUyouwh&crManicahad

2 ~pl~~~~~~~~~of~

3 Offlarsattk mgntc=y?

4 A ?btsubjaztcameammd?mtichowtbat-partofthe

s leasonwhyBaIycunicwasupsctistbatMo?li~Lrwinsky

6 apparcwly found out that the Rcsidcnt was in with another

7 appointment,

8 Q Okay. AnddidButyCMctellyauhowManiea

9 Lminskyhadfomdtbatout?

0 A bt ‘ swk!ztbc&qpticmauncin,thtit- ’

1 from tk offica.

2 Q Okay. Did&ttyCurrictellyouwhat&nica

3 ~~~Offl~~~

4 A Notq&f!icaNy,otbcrtbcmtkfacttbmttk

s officugawouttkinfotYmtiontoMs.Lminsky.

6 Q Didtkrmcoftkohrqqmintmmtcamcupin

7 yourcolllvamtiaJ WithBetlyChiC?

8 A Yes,itdid.

9 Q What was it?

Lo A ~h&md&.

:l Q AmddidBatycIlrriet&yin~tba.tMatia~hwiasky

2 badfoundoaltthattkRcsidentwsswithEleaaorM~~

3 A Yes,lmt’&m.

:4 Q WbtdidyoumdhrsagCantWiliimsaytoJ3uty

SChITiC?

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3357

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Imre:Gmndharypnnxxdmgr MultiI

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1 A Atthispolatit somchowgotontksubjecttkt

2 itmayn0tkvt~tkOffiC%MdwboarCtlybKR@

3 thisupI’maat1OOpctca.itrucbutgivuxtktimch=~

4 tkCbapro*imiryOftk~t=ltS~tktilttC

5 Ms.Mmblcsbcnh&up8ndtktimeMs.~rhrmduptt

6 waslbctMppmit’spossiblctktMs.Lnnirrtkycouldk~

7 obKrvcdMs.~goisgh.

8 Q Ycntsaidarkrtktwtmyouspaktooffifcr

9 tfallhe-8ttb8ttimc,bcwustatiugtharhtdid

1 0 nosncallwbabukhndgivultkRcridaotrloatium ’ _

1 1 auk AtAtpoit&didkheyautktkbnd~it

1 2 out?

1 3 A wknIquestiaoedbitn M,kC8USCIVJUH

1 4 kckouttotkau%bwstgatckrrkiitwaspotsi%lcbut

1S k wasn’t 100 pawtt surt.

I6 Q -Ilmtwnt8ftmyouspdcctoBcQycurric?

I7 A Ycs.ma”ma

I8 Q Auri&k We&letsgobcktoyow ’

1 9 convcrsfl~tbarwithBatycltrrit. soba.Siiyou

20 dor~tWiihm8aphiwit0batktthis

2:1 itIfonrrstiarcaMkvccomch-Mo&arJBhkycati

22 kvcobtaitx!dtkinfanultioQinotbtrwaysainanotha

2.3 way. Didyoudlbuwhettkitldcrwaywas?

2:4 A Wc&Idm’tknowifitwasmctkt~told

2:5 kztbat. ~ok~t~~I~‘t~,butI~

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~owthatthc~f~amneupinthccloscp~~tyM,th

appointments. It was possible. Betty Chic ssmcd to agree

with that.

BY MR_ WISENBERG:

Q Wcrc you ttyitq to protect officer I-ia!I?

A No, Sk.

Q I’m not saying there would be anything wrong with

that.

A No, I’m just saying - well, in a !&uatian like

this, it was man of a fact finding. But on the same token,

I certainly wouldn’t have given up Officer Hall at that

point.

Q Okay. Given him up, in other words -

A I wcwhint’ have lna& an accusation tb a passholdl!!r,

sying that, “Ye& you’re right, he did wrong.”

BY MS. WIRTH:

Q And you raid Betty Chic sumed to be satisfied

with&at? OrcalmcddownbytbcnorA AtthispoinSImadctksuggestionthatIwas

goingtogooutasd~totfieofft~justt4ma(c~

that they didn’t in fact give out any infhtation and she did

seem satisfied with that.

Q Didthesubjcctofmymcb+fycdevcr~up?

ordisciplined?

A I believe Mrs. Curtie said something the effect

P8gP July 23.1998

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UuttkRaidentwassoupoetkwantsMmebodyfmdovu

this. BItt1kindofnadtuaddthis+tkt~tnophntia~

mindwasIthiakh&*obmyGod.=aKhdywiukfnedma

this.”

Q-7

A llmtsaottkwaythiqsar:dcmc,~tkmtinow ’

-

Q BdunhgtktbrcRcsidmtwouldntktkmcm ’

fmt8andmd@ ~tktthisisoutofpnqmicmwtk

iuchkltQww7

A Ithinkitwaskhdofattofpmpatiollfortk

inci&aL EspshllywidlautQiasrulia~tioaar

factfiadiaBlL&hl.

.

Q Okay. Wastbatan@iugektaboutyour

conviz&onwithBratyctnrietktyoutt!mmtkr?

w~~~~u~t~t8~~~~

it&mtqt&ornotspakingalxnttitordliogtk

oRiihdvaimottospmk8bautit? Anytbinglikc

that?

A Tlmtwuputofmyca~~~ti~Mn.cunic

IcxplaitlcdtohrtktI~rclltkoffiitktyoukww,tokindofkccpittlncktkirkL

Q DidskukyoutoQtkt?

A Yu.maam. ’

Q Wlmdidrhemy?

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!S shouldnt’ talk about the Residaes locatiat.

pagea

A sbtaskcdmetomkestmtbattbeoff~ioas

didnt’ give out uly infolmuiotl on tk Resitktlt as fnr

as1ocatiiYclsndwhohisappintmentswcre. AtldIcxplaimzd

to her &at’s preay much our policy.

Q lXdsbcbavcanytxmversationswithyouabout

wb&krBIyant&0UldSp&abwttkincidentth8tday?

A &t tqxxiftdy, no.

Q Wasthuccmydisassion WbatraevatKtytiYEht

&ywithsnyone8boutwbcthcritwouldbcagoodi&athat

tbc pcoplc involved not sputk about this incident, not

di~uS!%it,tX3ttelltkaOrytodbers?

A I wuat out to tk gate with mt wihtm

~~~~~1~~~0~~~~~~

this.

QW

A l3cmuscalotoftkstorymUld~vcbccntmcdm

nmorsamdI&m’ttbinkitwasfairfar8oybodytoeq#p:im

ruuuus.

Q Didyouhsttuctthcofftcustodothatbeautseof

~~~C~e~~d?

A NQ,ma’ttm.

Q Did&acyCumiecvcrstatctoyoutb!tbc

imcichtabouldnotbcdiscumdoritdbojld&kcptquict?

A ktinsommywords,butshcrcitaavdthat~

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BY MR. WEXNBERG:

Tms’ two diffault things. ttmgh

wtltlm.io!l.

AW

Q OncismsboddnttalkabaUwktlmppcmdtht ’

day, tk wkk “incident” Do you -lkdistinctioe

IltllMkiOg? ’

RijJbt. SUIC.

h4R.WlSENBERG: AndktmcbackupforasecmdPardonmcforbnningiu.

MS. WIRTH: lbntr’ ati right.

BY MR. WEENBERG:

Were ’ still- chmoh!gically. yaurc’ still up

&lefewithsagkaatwilliamshlJurviqgyourfmcul~~

witllButyclmkcmst?

A Thats’ cmmzt.

Q Now,you8WifiibW%day,vaylimirdscapc

yCIufccalltiult?

A Right. Absohtely.

Q Youmrccmly~thnaboutwbattkRai&at

said. corrm?

A Thmtwasonmysaxndvisit.

Q That’s tbc second visit of the day.

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A Yes,Sir.

Q Ailright. JustgcttiqthatA l’hatdidnotoccurduringthisvisit.

MR. WISENBERG: Okay. Go almd. Sorry.

BY MS. WIRTH:

Q Okay. So getting back to the qucsticm that 1 was

asking you before --

(Interruption to the procedings.)

MR. WISENBERG: Let the record reflect that Ed Pg

of our Offlcc, of the Office of Indcpcndcnt GMmsel, has

cntercdthegrandjurymom.

BY MS. WIRM:

Q okay. ~geningbcktotkqucsI.ionIwas

asking,wasthean@ingthatBettyCtisaidtbat

inspiredyouorledyoutobclieveitwouldbtagaadideata

tcU your OffIccrs not to speak about this incicknt?

A NotthatIcanImumbcr.

Q Okay. DidyousacthePrcsidcntattbattimcwhen

you went to se Betty tunic with Scxgcant Williams?

A No, ma’am.

Q Wknyuuleft,wasthedourtotk&alOffia

StiIl sllut?

A To my belief, it was.

Q Didyousceauybodyelsupt&ebcsidesBctty

Cumie?

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Pqc 23

A h ktty CutTies’ offtcc?

Q Right.

A No.

Q Otkrthimthatphatograpbawhoyousawattk

Wybcglmiag.

A h~tkb@nn&&whodcpanedshortlytba=ftcr.

Q Allright. WhatdidyoudowhenyoulcftBctty

Cxuxie’s Office?

A MyslfandSugcantWilliamswentbacktothc

mgatc.

Q When you left Betty Cunic, was it undastood

bewecnyouandherthatyuuwouldcome,backandrcpartto

bd!

A ItoldBcttyCu+caswcwwc&pahgthatIwas

goingtogooutandtalktothcoffl~audmakesuretky

didn’tgiveoutthcl~~oftbcPrrsidartar~yofhis

appoia~tsandskattbatpointwassatisficdandIssid

SCQIC%gtOtbCetfcathat~I~&lOCWiththat1Will ’

aumback Idcm’thowmywo@scxactlythat1saidtuhcr,

butfdidindi~tbatIwouldretumkcktohcroff~cc.

Q Wcreyou&Uingkrtbatyouwcagoingtomakc

smtkttbeyhadnotdcmctkttktdayortbattky

wouh’tdoitintkfutux?

A Kindofboth.

Q Allright. Sowheredidyougonext?

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A Backtothcmxthest gateortlaibz.

Q DidyuucvcrspcaktoOfficcrChinuytbatday?

A IbelicveIdid.

Q DidyouspcaktohimonyourwaytoBcttyCurric’s

office?

A Probablyjustacknowlcdgaihim,myselfandsergmU

williams,ontbcwaytoMrs.curric’soffl~thtfimtimc

Q DidyouspcalctohimantbewaybackfrumBetty

Curlie’s OfTice at that point?

A kitkspoketohixutbsttintcinaclmowlodganeat ’

ortoldhim,askcdhim-tkewasapoinfitwascitkr

aftcrthcfintvisitor_I’mjrrmpingalitllcbit~of

lZl@fherr,aftatbcSCU&ViSi~I&CdOffiaZrchiaay

ifkkacwti~goingou,whi&obviou4ykdidkmnv

wbatwasgoingmkcausekma&tkpkaecallb~

WilliamsandksnidyathendItid,WcU,kt’sjustzmkc

smthatwckindofkmpitunckrowkts.”

Andtkakdidmakaainquirytomcattktimc

iftbcoffim~introublcaadI~4’IQo’tthinLro.

sol&lhgtotktcfT~

Q Okay. Ihenasyoukftktty&rric ‘ sofftcc, ’

~yuupruoD&ddowntotktrailcr. wktkryuuspukc

toofficcrChinayorrKttatthatpointA Right. It was,oncof the twotrips. wt.

Q okay. Whatyougotdowntotbewaikr,was

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inrt: QnndhuyI’mccdm~ Muli

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pagcz

Sergeant Williams with you?

A Yesma’sm.

Q DidyoudiscusswithsagUmtWilliamsontkway

downwbatyouwoulddowhmyougottotktraik?

A Wcprobablydid. Idon? rrrmrrmiaspCS3fiiyi.f

wcdid,butmorethaalikelywcdid.

Q ~~~&~~got~~~

A IjustbasicaUyrcasnn#itoOffiiccrIIa&wboat

thattimctomcappca&visiblyupsct&atcvaythin%was

tm&rumaal. AsfarasIwasconcaned,tJ3eincidartwas

prGt¶y much msolvvd

Q Didyouaskbimanyquestionsaboutwkthad

happanedthatdafl

A No.

Q YousaidearfintbatOffi~Hallatthatpoint

did not acknowl+ that k had givu~ the P&&t’s

iocationoutm.uithatwascarlicr. Didka&nowlc&cthat

atthiS&lCwtwnyoUcamCb&t5thCtraiid!

A Whcnkcamcback,ksaidsom&@1m&ht

k~butIda&xuncmkr.” Andkalsomadcasu@&m

th2Uitmighthavcbccntalkdaboutamongtkoffian8&

Ms.Ixwix&ymaybavcheardit. InmymindocfIwasn’t

suiCfMS.Lnvinskyata+m&idbCUCntkuailer~

outsi& of tk trailcrL

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Q Oh.butyoudidn’tlcnowifsbchadbaa,inatthc

point when it was discussed?

A Right. Nor did Off&r Hall rcmunbcr.

Q Did you klicvc Officer Hall?

A Yes.

Q Did you speak to arry of tk other officus ksidcs

Offliar Hall?

A Theothcrofficcrswatallprescntatthistimc.

Q Did you speak to Office Nicdzwiccki?

A YqIdid.

Q Wktdidks=yhadbappcnd?

A OfficerNi~basidyhadthesmtstory

that OfEar Hall had.

Q hkaningw)rat?

A ThatitwasaimostuncnxainonhowMs.~

had 0-d directly or indixcctiy tk location of the

President.

Q til right. what --

A JUROR: ticusc me.

Ms. WIRTH: Yes? -

A JUROR: Excuse me. Did you speak to the off&s

individually, sepamdy, or together? I

trailer.

P4F” hIly23,1991

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Page 2’

THEWITNESS: lkywneaittogcthcr.’

AmOR: l%isisHaUandNic&wi&i’!

THE WrrNESs: And that wds anotkr offim,

offii Par&?, p-t. There wuV! thru Offlazs.

Ye& sir.

AmOk -hankyoU.

BYMR. WENBERG:

Q Doyouknow-Ornot~twi~t

have questioned tkm Sparatcly kfofc you got tba?

A I think it’s very possibly, but I don’t know for

sure.

Q~Aaddidyoudi!#x~withtbcmjusttkqtvsticmof

wktkrh!fs.Lewinsky~tkRcsi&nt’sl~cnla

alsotktwinthiagsofbisloautionaDdtkf3cttbat

ElamarMaadaleA lkywatgmupuitag&kr. Imitwam’ta

scparattsubjcct. lbcy~both-itwaslikz8ninclusivc

discuSion.

Q olary. AaditwaSwktabout~Mandaft,that

~~~~~~H~f~~~~~~~~tk~

banintkoValoruxwithtkPmsi&nt?

A 7batskzwasintkOvalOffkcforatour,I

kiieveisthc&rminollogytha!wasus#L

BY MS. WIRTH:

Q Atthispoint,didyoutetithcofftcusthatthcy

page 28

1 should not discuss this iaddmt?

2 A Ibeliew:ItoidtheDfficastoussomc

3 diMon.

Q Okay. whatdocsthatmcan?

.A BasicaUythatanytimcthatthcytalkaboutthe

Presiden~thcynadtokcarcfuionwho’samund

Q Butwithrcspaxtothisparticuhtrincidcn~did

yoUgi~thCmsn]t ~aboutwkthcrtkycoulda

should spca_k about it?

A I believe that was Sageant Williams who did tkL

Q Wbatdidksay?

A Prcttymuchthatma&dtokindofkazpthisql&

bccausewedidn’twanttknmK3rstogctQutonanythingthat

did or didn’t happea.

Q DoyouknowwhysergtgntWilliamsaaidthat?

A Ijustthinkitwasjustcommon smsthatma&him

seyw

.Q Hadyouinsnucted~tWiamstosaythat?

A No.

Q D~~jo~~~~i~ti~~~ .

should ksq, this q&t?

A It’s possibic. I don’t kGcvc 1 did, but it is

possible that I did

Q Allright. Whathappaxdaftcrthat?

A Imatbackandhadasecondm&ingwith

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Page 3a

1 A No, ma’am. That was not brought up.

2 Q AU right. !h, anyway, wtting back to the point

3 oftkstorywhcrrwewcff,youwcre~yourwaybacku,

4 Betty Currie’s off&.

5 A Right.

6 Q To talk to k. &I you know if you saw officer

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Page 29

Mrs. cufrie.

Q Did you go by yourself?

A &S,n.la’~.

Q ~youknowwktkr~~ytimeqMihbatpoht.

sagaratwillirmrshadspaLenmtbeRsi&nt?

A At that p&t& no.

Q Doyoukncwiftataintkdaykdid?

A Thisiswkrefneedtojumpalittkbitakadin

time. hyauwsntmctodothatrKlw?

Q Just briefly.

A Okay. Aboutsw&kagoIkardammorthat

sergeant willisrms may litwe bad 8 eonvusation with the

Rsiiktbt kc

Iapproackdsageant wiuiamstm it. i3cqcalt

Williamsmadca staummttomtktwhkwasinsa&

Mrs.ClmietkfvsttimetkttkdoortotkovaloffLx

wasidtqpenalittttbitandatthatpointItald~t

Will.iamsthatkneaJedtatrilkto~icg;i~pobple,tk

sonet Scfvicz lqal colzr&.

Q Okay. !%tknA But during that day, that had not ken brought up

tome.

Q Okay. But !Sqcant Williams did not go so far as

totcIlyoutbatkkdspokcntotk%si~torkkd

not?

cbineryontbeway?

A ~ISUIC~S~W~~BL

Q Did you speak to him? DO you remember?

A Not that I nzncrnbcr.

Q Are you friendly with him?

A &?&Iftm.

Q Is it possible &at you spoke to him?

A It’s very possible.

Q All right. Wkn you got to Betty Curric’s office,

what did you do?

A &ain,hh,Cuniestoodup,skwasscataiatkr

cask. Iknockcdcmtkdoor,Iwalkedia. Skclosedtk

doarkhindm.

SkkdmtahascatandIcxplaixxdtohatkt

I - or basically rcas%Kdtokrtkttkoffl~badbacn

told not to talk about tk Presiht’s location end wk his

appointments wuz and she was satisfti with that.

Q Did you give kr any more information on what had

kpperla! that day?

my 23,1998

I

1 A Did1ginbcranymosiofonna~? No.

2 Q Okay. Didyoutellkrtktyoukdrpdrnrmtht

3 offkas iovohRd?

4 A Yes.

5 Q JXdyoudlhawhatyaurqriniaawuofwttatbad

6 kPpenad?

7 A We&at&atpoinritwas#rmmht~upan

8 ~~~~~it~a~~of~~~tit~

9 passibk that sbc cwukard tbc offkas. It is pnssibk

0 tlmtMs.hwinskyobsemdh4s.Mandakccmcintotbcwhh

1 HOU%.

.2 Q Okay. Andt$iscoawzcrrion,jttstyoumd&gy

.3 cwriewemfnemlt?

.4 A Yc%udmn.

.5 Q Anrigtn Howwashh.Cmic’s-at&at

,6 poiDt7

‘7 A Smmvhatnxacdm. hfact,Iwukisayforhck

a ofaba.ewodaamal.

9 Q oicqy. And~tdidsksaywknyoutoldbawimt

!O yoUtO~bcr?

!1 A Skwas-iamyqrinionskmtsatif&ti&

Y that aplan&tial.

!3 Q lXdthcsubjcctofqbodybc&disciplimdor

!4 fpcdwanywogl&ctbatctnnCup~tthis~?

!5 A No.

plgc31

Q whathippanedmrt?

A Justrightabauttktpoint,Ikardtkdoorfmm

tk Oval Office_ which I’m sure you% aware here’s a door

right khilrd Mrs. Currie that leads to tk Oval OfTice. It

0pencdupanditwastkRsidcnt.

Q Olcay. Andwaskalonc?

A &s,ma’m.-

Q Andwktdidkdo?

A Askstoodattkdootway,bothMtsCurricaad

0 nlyaelf*wcstoal Mrs.clmiein-mctorkJ andtkRcsidait-kusdtkword”~wktti

2 cxactwordsunrr.Iklim,andIkvctostxcssIbclicvt,

3 itwasmIkpeyouuseyourdismtim.”

4 Q Way. Aoddidyourcqndtotk!?

5 A ~bdievc~said,“Yes,sir.”

6 Q CanyaiUltkgrandjurywkttkR&knt’s

7 manncrwasw&nksaidtkt?

8 A Ag&,)fOUkn~,fOrhCkOfabCUCrword,I

9 k&vczK#rmaL

0 Q Hadyaumrtahdtotkhsidmtkfozc?

1 A Yts,makl.

2 Q Didksayanythiqmcethmthat?

3 A No.

4 Q AftQyousaid.“%s,sir~wktbappared?

5 A TbacwasapauseattktixncandIkvctogokck
3361

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Page 33

bmyfoctiags~this.Ifeltitwastimcformet6leavc,I

told evetybody, “Have a nia day,’ sod I left_ And I cloud

tbedoorbehindme. TkdoorwasclosedandIclosedit

behindmc.

Q Okay. ~whe=didyougotkn?

A 1wetltbackdowointo0uropaatiaas offtL% which

isintbebasementoftbeOldExecutivcOffieeBuildiag.

Q Okay. DidyouspeaktoOffimChinaycmtbcway?

DOyOUkXlOSC

A Again,tbat’s-itwasdtkfoothartimeortbe

timebefolc,buttmeoftbetimesIkoowIspokewithhim

Q Anditwa!tanthatoccadmtbatyousaidwhat?

WheaeveryOUhadthetcOn~

A whea~~k~dhimifhtknmwhatwas$oingon.

dwiously he did know what was going a~, I said, ‘Hey, just

kind of keep it un& your hat.’

Q Okay. Didyoucvergobacktothetmilerthat

day?

A No,ma’am

Q DidyoueverspeaktoSeqeantWiiamsa@about

this incicknt?

A Letcronintbeday,heapproacbedmeandaSkedm

ifIhadaconversationwiththeResident_ Andatthat

time, I just kind of shook my head and I said, ‘Hey, just

kind of keep that to yourself.”

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1 Q Did you tell him what the Rtsidcnt had said to

2 you?

3 A No, maam. ’

4 Q Did he ask you?

5 A No.

6 Q Did he tell you that he had had a conversation with

7 the President?

8 A No, xna’am.

9 Q Did you discuss the incident with anybody else that

0 day?

1 A Yes, ma’am.

2 Q who?

3 A WhcnIwentdowntoouropemtionsoffice.theR

4 was at least one other lieutenant in that of&x, I believe

5 thereweretwo. Ihadthelnleavethefoox&leavetheoffla,

6 Ilockedthedoorbchindthcm,andIcaliedmydeputychicf,

7 Charles O’Malley, at his home.

8 Q And you reported the incident to him?

9 A Yes, maam. ’

0 Q And what did he say?

1 A He pretty much agreed with the way that I handled

2 it.

3 Q Okay. I&l-he say anything else?

4 A Inrcfereoa to?

5 Q Anythitq that you remember.

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A Nanan-.’

Q Wrs any pqmvork cxatai on this incident?

A hhmaun. ’ Tbatwasoneoftkissustbattk

&putychicfaadIdiscuzsdmit

Q rMwktdidkq?

A ltwasmy neumrmendrtianrohim,oftourpck

wouldkvctkf~say.tktaopqmworkk~tcdd

fuassmrmwritingsandwi~tktkaskalifmyfaliagva

tktthis~was~awwithandIsaid,“Iklicveitis

ovuwitll”

Q WktwastkbasisforyorPdviazthatthzaot

kMYprpawalR

A TktMrs.craricwassatisf~wirhtkwaythiags ,

-balmjU.

Q Ifyouwuetofiuouturypapwotk,wktfonn

wolddyouuselxwktA F’mbablYagomt mamxaadmwhiehisa

suuKltud-ftmn8tlditwoul4ikvogowmaly&puly

ChkffTWlmC.

Q Toyourknow~ksanybodyfillcdoutaay

papawuk al this incident?

A Namaam. ’ Tomyknowkxigenopapmvorkksbem

doac

BY MR. WISENBERG:

Q Wktwoukidmthmvebaea,likee-would&at

plrgc31

manomndumkvercf~acomplaintbyMs.Cun+~

somuhiq tkt occullul?

A Wdl.sinceIwasinvolva!intbeiss~ilwould

b~kll~-fromlllCtOlIly*UtyChidaphirriag

what my iavolvrment would kve bun in it and I probably

wouldlwcbadtkscqmntandrtkastOffiarHaUtircr

mano a~ it. And+.ssiblyOffiiw Cbinery, beaus k

leccivaltkcallflmlMrs.cuiTic.

Q WouIditi&bamtkxnmalpracticcfortbis

kindof~ttobavtwrit&mago~tmmmrandum?

A If h4rs. Currk wasnt ’ satisfwd. it would kve &

tk IKnmal practia.

Q OLny. Wa.~~ourdccision~to&amauamnd~

influenced bY tkSt’s eocamaltstoyauabollt

discrdim?

A No. sir.

Q ItwasinfluawalbytkfacttktMs.Chie

scanal OtisfCd?

ARight.

Q WbentkRaidmtwalkalout-orwalkedincanz out, yw and Mrs. Curric stood up, You oestifd?

A-.

.Q Anddidkeaybtkdowwayadidkcanccbsc

@yW?

A Hestood~tiatkdoorway.

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Page 3:

1 Q Didkaskyoutoconzclosctohim?

2 A No, sir.

3 Q Hadkbccn-youhadjustkendiscussingthis

4 xnattcrwithMrs.cllrric,isdlatconect?

5 A W’SCOmXt.

6 Q Iic didn’t say “What’s going on” Or Snything liLc

7 that?

8 A Mrs.Currie,assheiatroducedme.said=Ihis

9 istbcpcrsoninchargcoftkunifomcdforces”or

11D ‘the mifonnal divisiti and tk situation’s bzn handled by

I 1 hiln”orsom&ingtothateffect.

1.2 Q AndthcntkPmsidcntwentrightintohis

1:3discluion commCn~iSthlU-?

114 A Ye&sir.

1:5 BY MS. WIRTH:

II6 Q After~ouspO~*yo= amxnandu, did you have any

I’7 further conversations with anyone that day about this

11B illcant?

I!3 A Yes,Idid.

213 Q who?

2 I A Anagentfrom-andIusetheword~,butdoI

2.I2 oad to explain what -is?

2:3 Q Yes.

240 A~iStilCiipltS’ umnnandcenter,whichisan

215 offia in the West Wing which is directlflPage 38

I ___ It’s the agents’ down room.

.z Q You’re talking about the president’s protective

5 detail?

1I A Yes, ma’am.

‘5 Q Whowasthatperson?

(i A At the time of our interview, I didn’t remember his

7 name but I do remember it now. I believe it was Don Mite.

I1 Q Don what?

5t A Mite.

I() Q Could you spell that?

11I A I have nd idea.

1;1 Q Okay. Do you know him?

1:I A No, ma’am.

14’ Q IsthisthefUsttimeyouspoketohiln?

1.5 A ThZttIrCInUTlba?

116 Q That you Aalow of.

1’7 A sum. Imea&I’msureI’vespolcenwithhim

1:

I!

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2

2:

2:

2s

2:

8 before, but that’s the fvst time I tuncmberspeakingwith

9 him.

D Q He called you?

1 A Yes,ma’am.

2 Q Whatdidksay?

3 A Atthetime,I remember this pntty good, at the

4 timebesaidthercwasalieutcnantinMrs.Currie’sofia

5 and he wanted to know if that was a problem and I cxolaincd

p4F” July 23.1998

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Page39

to him it wam’t a lieutenant, it was in fact me.

And k said, “Well, was there a problem with one of

my agents?’ I said, “No.’

Andksaid,“DoyoumindifIaskyouwhattk

problem was?” And I said, “Well, it was a pcrsoaal problem.

And again, k &satisfti with that.

Q Any further discussion?

A sergeant Williams approached me in the hall.

Q Tbatsamcday?

A Ycs,ma’am.

Q Andwhathappcnedtbae?

A Itouchedupontbatalitiewhilcago. Heasked

meifIhadaamvcrsatitmwithtkRcsidmt.

Q Ri#tt Okay. Anyfintherconvcrsati~thatday

with anyone about this incident that you rccaU?

A No, ma’am.

Q Okay. Have you discussed this incident with

SetgeantWilliamssincethatdayotherthantkone

conversationthatyoumc&mcd~tawcekorsoagotbat

~‘~goingtotalk&outinaminute?

A He’saskedmealittlebit,youknow,aboutwhat

kdhappenedwknalltkstotieastartedbmakingbut

nothingasfatasintodeUilsatall.

Q Whenka&edwkthadhappenedwhatdoyoumean

by that?

Page 4c

A Wknthestoriesstartedbreakingaboutour

involvement in this issue and the issue came up, k

approached me about it.

Q And saidwhat?

A Just, you know, something to the effect that,

“Hey,isthisgoingtoa&ctus? Arewegoingtohave

totestify? nlattypcofthing.

Q Otherthanthattypeofconversation,any&ng

else?

A No.

Q Didkeverreviewanyoftkdetailsofwkt

happened that day with you?

A No, ma’am.

Q Atanytimesimxtbatday7

A No,ma’am.

Q HowdidyoukartbatSagauttWiikcl&cn

tkRcsidentthatday?

A. ‘That-Idon’tknow. lhat’skindof-Imesn,

how do I think Seqcant Wiiams found out about that?

Q No. No. Yousaidaboutawcekagoyoulmda

discussion with Smgcant Williams about wktkr k had gerezl

tkPnxi&ntanditwasbasedonsomcthingyouhadkard

A Right. &miqthepastsev&-coupleofwcdrs

myways, I’ve ban gathering information for one of the I

subpoenasthat’skenissuedasfarasourpost@sare I

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xnrt: Grandhay-gs MUll

coaccmedaadmeoftbesagarnts-well,Ihave~

scrgcsnt&gnaion&isdctailwirhmc,ktoldmtktk

kardthatruxInx.

wbowstkhugcant?

sagcant Tam Mach

MM

M-a-c-h

MS. WIRlH: M-a-c-h

MR. WISENBERG: Pardon me just a minute.

(paust.1 __

BY MS. WIRTH:

Allright okay. otkrtkathisiacidmttbat

youve’ tcstifid about today, bwc you bad any 0th

alcoun~or Icw3wlcdge of any cnmuntcrs with Moeia

Lcwiasky?

A 1mmzmbzrwlmskwasass@KdtotkEastwing

of tk White House.

Q Did you know kr?

A Nothing more than exchan&g, you know, khs,

thattypeofthing.

Q Okay. Didyouevukaranytbingaboutamy

&timshipknmnbcrandtkPx&kntattktimetkt

skwasass+dtotkWhitcHoustorworkingattkWhitc

House?

A ~mezm,ofcoumch’ekSfdthingssince,butat

Page 42

1 thetime, no.

2 Ms. WxRlH: okay.

3 BY MR. ~‘ISENBERG:

4 Q I’ve got a couple of quarions for you. Captain

5 Pun&. Now.yousaidtbatyuuwazor&naUycalkdan

6 this day by your opcratidkutamnt. who was that?

7 A Liaumant Ja Stump or Joseph Scmp.

8 Q Okay. Howdoyou spellthat?

9 A S-1-ump.

0 MR. WISENBERG: Let me show you ml quickly what’s

1 +n ma&d as JJP-I.

2

3

4

5 Q

6 A

7 Q

(Grand Jury Exhibit No. JJP-I

was al&al for i&ndf~Iion.)

BY MR. WISENBERG:

Tbosc me yap inithls. JJP, comet?

That’s carrox

AndthisiskindofaroughschaacoftkWcstWing

8 and it’s a map with preprinting and sombody’s prined. also

9 bandprinti and that’s not your printing, is it?

0 A No. it’s not

1 Q IwanttosbmvyoutkOvalOffibcandyou’ll

2 see 8 door. Assrrming tk Oval Office is 0 clock. you’ll St

:3 a door going out at 1:fNJ.

‘4 A Right.

15 Q Tonnarcatkthatismmrkalonthismapa.sraxptim

P8gC July 23.1998

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Page 43

arm 1 and there’s a little sqrnvr or nxrangle that says

BC for Beny Cunic, or I’m going to say for Betty Currie.

DOyoUSiUtkt?

A Ye&sir. Ido.

Q Okay. Iwanttojustgdforussothatwc’ll

know,~youmetwithButyCurric,Ithinkyousaidm

each axasion, did sk clcx tht door to kr offiac?

A Ycs,sir. hdthatwouldkthisdoor~.

Q okay. ‘htistkdoo~?

A Ye&sir.

Q lkre’sanamnvgoingthroughazcrooranOrigbt .,

YKarthtdoor,right?

A Right. Thcdooradjaceattothchalhy. .

Q Okay. Imxdarcdpea Wouldyoujustdomctk

favnofmarkhgwitharcd~appmximatclymthismap

wtlaetbatdoorwasthatskcloSd?

A Circle it?

Q Yes. Adotorcirclc. Okay. Asfarasyoukxm,

wasthac8nybodyotkrtbmFkttyclxricin-notanlntirtg

t&ChmlOffke,butjustinmx$iooarca1,ikludiqtlx

inthoroff~tawk~~NancyHamichusuaUysits,wmtkx

anytmdyelsrctkrcotkrtlmyouandononcoccasimyou

and -

A ?htpbo~her.

Q -and!kgCantwii we~aftershcgotlid

Page4

1 oftkpbotagrspha.

2 A Right fomykmwbdgc,thcwasmbodyckc

3 prcsmt

4 Q Okay. Oncitkroftboscma%gs.

5 A Ooeitlwoftke. Tkfusttimitwouldk

6 SagmntWi.myselfandBcstyCmic.

7 Q WY.

8 A AndtksccondtimeitwouldbavebanBcrtyChic

9 andmyxx

0 Q AndtkntkRsidehlcamcoutinhatsmmd

lImuin&

2 A Yes. sir.

3 Q Okay. Tbankyou. Thtonlytimctbatyouspokto

4 SugmatWillhmsaboutthisissucofuhtbanotkm&

5 kvcsaalkRSidcnttktdsywastkoocymJ’vcecdm

6 us&aaabudy,ca~~~t7

7 A

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0 two?

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Ya. 0ir.

MR. WEENBERG: Gkay. Thats’ all I bad.

culwcaskyoutosrepoulsi&farjllstallmmmta

THE WITNESS: sm. Inlkklhvay-?

hS.wfRm Yes.

I&. WISENBERG: Yes. Just down tk hallway the.

4 We’licrmc~youinaminu~atw.

5 Cwimcss excused. Witness mxtlkd.1

J

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In rc: Grand hny Fraccadings MUlti-PflgCn July 23,1998

4

Page 4!i Pag 47

1 MR. WISENBERG: La the record rrflcct that Captain 1 1 be’s just &parted frolo the elevator. He’s two minutes

2 Purdiehasrcmtcredthcgraodjury~. 2 away.”

3 MadamForcpcrson,~tbcreanyunauthorizrd 3 Q Sosom&odywboisafairlyhi#$&vel4 pcrsonsbac? 4 A Sure. Depca~dingonw+~~tbcpascmi.s.

5 THE FOREPERSON: No, tbcre a~ none. 5 Q How about son&ody who is not an off&l anpla

6 MR. WISENBERG: And what’s the other questian? 6 butwboisavcryim~tpcrson,likcaVemonJordan?

7 Andmdohavcaquorum? 7 WhatifaVczoonJordao8 THE FOREPERSON: Yes, wt do. 8 A Idon’tbclievr-mygutfaelingisthatwO~dn’t

9 MR. WISENBERG: Thank you 9 be appropriate to tell.

0 MS. WRTH: ’ Captain hdie, I’d like to remind you 10 Q Okay. Now,howabouttbcidcaoflettingsomebody

1 thatyouarcstilluo&oattl. 11 cvalin~thatfX3ila?

2 THE wlTNEss: Yes, maam. ’ 12 A ~kamcinthattdcr~tktimc,sir.

3 BY h4R. WISENBERG: 13 Q Istbmapolicyqainsttbat?

4 Q Thercarcsomcqucstionsthatthegrandjurors 14 A No, sir.

5 wantedaskedandIwillaskthanandtbeymightalsohavc 15 Q Ennthoughitputstbcminapositioowhcrethcy

6 some f& questions that they’ll pa3onaUy ask. 16 might be molt than likdy to bear the Pnsidmt’s location?

7 A Okay. 17 A Well,tbctrailerisactuaUyamaineotranapost

8 Q Whcayouwcntbackatcithertimcthatday,ti 18 totkWhicHousegramds.

9 youweretaltiwtOtheofficcrsinthchailer,didyou 19 Q Okay. ButItslccitalsopcoplcshouldn’tbcina

0 rcprimandthcmatall,mildlyorotbawis,fortelling 420 positionwkrethcyov&caranaSccrctSuviccradiotk

1 anybody the Presidc!nt’s location? 411 Pfcsi&ttls location.

2 A N o .

a

d 22 A Thrt’scora3.

3 Q Did you repximand them in soy way, mildly or not, #

23

4 II QIsthataa~~&?

about putting themselves in a situation wberc somebody could 14 A -hat’samvX

5 overhear talk either among offtars or oo a radio about the d

4E Q Now,~Iwanttoasknowisdidyoufetlifthe

Pagch

1 onlyisstlcwnralldI’maottTyirgtodowttplaytkimpartura

2 ofif butiftkmlyissucwas~tkResi&tt’s

3 locatimtoscm&mdywboimdbcuttotkWitkHoluebefac.

4 wasnotcats~rtkat.didymf<battksituatim

5 wknyouuIucoatksanGtkkindofupscmtssof

6 Mrs.Cmicmdtkhsidm~amrdingtowktsksaid.

7 wnskindofcutofproporthtojwtsomcbodywastoldwhc

8 tbc Ptmidatt’s bution w8s?

9 A IfIuadengadtbtquesdaaccarectly.iraily

1 0 didn’tdvcitmyrbwgbtO~tbyurerrupoctIjust_

I,I IbcfsctthatskwuupsamuevidmtOmcwhsnIf~t

1.t visited her.

1.3 Q Tktwmyourmaincaacan.

I 4 A Yes.&.

1 5 Q Ha~rhisevubait&mbdat,~tbckation

J 6 gersmmkd?

1 7 A I’m sux Yes.

1 8 Q Areyoumutof~wbo’sevakeotqhmukd

1 9 forit?

210 A Nottkt1canzmunbu in raeent histay.

I!I Q Okay. WbatwastbcbigdcalthnttheRsi&atof

712 tkzUai~Smaortkcxecutivc 8cCzuuytotkPK8klult

213 oftkuttiedst8rsatxVortkPIuhiattu!uesottpstSovw

214 tbeviolaticmofthispoiicy7

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President’s location?

Page 46

A No. I reminded them that they shouldn’t. Now, to

me there’s a clear-cut difference. A reprimand is done on a

one-on-one basis.

Q What was it exactly that you reminded them of!

A Irunindedthcmasagroupthatwhencvcrthcy’re

talking about the location of the P&dent or any

presidential guest, they need to be m nobody is listening.

Q Okay. And how tious of a rule is that in the

Secret Servia?

A You know, it’s a policy. I don’t know if I can

really come out with saying the severity of it. There’s a

lot of contingents that am in there with that.

Q Wou.ldoncwnti.ngentbeifit’ssomebodywhothey

know visits the White House a whole lot and saff the

Prcsidcot a lot, som&ody who’s fairly importan& would that

be a contingency * as an example, it wouldn’t be that

weirdofathingtosaywhenthcP&dentis?

A Well, really, by policy, we’re not supposed to tell

anybody where the President is.

Q Right.

A But I’ll give an example, if the Chief of Staff

ca~out,walksouttooncofthcpostsorMrs.Cunicwalks

out and says, “Is the Prcsidcot co route to the Oval Offia?”

It would be appropriate for the off&r to say, “Yes, ma’am, 5 A Innagr~thatanytbougbt WlmIfirst

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Page 49 Page 51

1 visitaiMrs.anrk;mymaincCnCUDvutMtsk~upod 1 A JUROR: Tbavs righI.

2 Mdskis8hi&#nnl6ngpassk~. 2 THEWTTNESS: Itw8s8boutswc&8goorso.

3 Q WIty&youtbinkskto~yot~mdyuucon=tm 3 AJ’UROfL I tt&zsmd. Thank you.

4 if1gcritwnn&wfiydoyDuthhksktddyuutktthir 4 BY MR. WDENBERG:

5 infolnMhntktMolliulmiatkywutuld~ttkf~tkt 5 Q DidSa8untWiievaeiiyautktk

6 EkerMavlJtwwithtkRuiiwfydoyuuthirrkrhe 6 pezxm&yovaksrdtkRcridart~~~y~~?

7 skraitkscrpccificswithyou? 7 A No, sir.

8 A AgniaIthioJctktwastkmotoftkpzublcaof 8 Q Ontktw

9 whyskwatups& 9 A No,&. ~~tW~~~~~t1

0 Q ‘Jk root of tk problem in what rose? Just that’s 10 just apkincd obcmt the door king Creckai. k cahrrd to

1 what kppczed that a# 11 goon. lwunlysurmhwktkwasgoingtodl~but

2 A h4rs.Ctaric%msu$sUandIbctir%tkt’swbyih: t2 I~~~~~k~w~tw~~t

3 wasupsct. 13 kfairmayba&

4 Q Okay. DoyouthinkskwasupsctkEIusit~ 14 MR. WISENBERG: Okay. Fair aunt@.

5 thktwoindj~,MonjcaLrmhpjcyrmdEfeaaorMmdpk? 1 5 Any*qmtimc’l

6 A Irrallycoui&‘tgiveanannWtutb@. WhatI 16 (Na rapoaff)

7 c.angivcM Mswcrtc&skw4supsd. 17 MR. WISENBERG: If tbao arc no mar: qucetions. may

8 Q YoukdmahmaiontbisissucOf~t 18 tkwitne3skorcural?

g wjI&ln$,assuu+tktscr8cantWiididt8lktotk 19 THE FOREPER!SONz Yes. k may.

0 RSidaltthatday- 20 MR. WISENBERG: Thank you vey much.

1 A Oksy. 21 THE FOREPERSON: You rur: excused.

2 Q Wouldoncoftkrrarans tktkmightnot 22 THEWITNESS Nomorcqucsthts?

3 volunrcrr that to you have to do with ranl~ tbc fact that tk 23 Ms. WlRlXz No. ..

4 Rcsidcnt would k tt&ing to bim about it bcfm k talked 24 MR. MSENBERG: No.

5 to you? 25 THEWrlNEss: Tbakyou.

Page 50 Pagt Si

1 A I know Sergeant Williams pasonnlly. First of aU 1 MS. WIRTH: Thank you.

2 I don‘t know for sure if k did talk to tk Prcsidmt. whn 2 THE FOREPERSON: You are excued. ‘hank you.

3 I 8f,JS‘X,Cbcd him about it at a lam datt. which wasnt’ that 3 (Tkwitncsswascxcused.)

4 langagofromtoday’sdstchctoldnrtbatth:daorurIbc 4 (whcrrupoa, at 4:04 p.m., tk thin8 of t&mony

5 Oval Off& was crackdl and at that point I told him that k Sin~pnsenccofafullquonrmof~GrandJurywas

6 medcdtotalktotkSuxtScrviftlepalcams+l.Andin 6 cottciuded.)

7 gcncaalitics. I don’t think that would have anything to do 7 L..l.

8 with rank. why k wouldn’t - if that in fact did bappcn and

9 I don’t know in fact it did happen.

0 A JUROR: Excuse me. Why did yuu advise him to

1 talk to counsel bccausc fbc dour had ban crackal? what2 prompxziyotl?

3 THEWrrNEss: WcUIbedkardanunortkt

4 SagcantWillhskdaconvcSationwitbtkRcsident.

5 AndISlpprcackd!SagumtwiBiaIns8balttbisnJmorandwten

6 ktoldmc&at~kwasinwithh4rs.Cu&onhisfint

7 visitwhichwasbyhim#lfIkbclimkmsby~in

8 th:offlicesttbattimcthatth:doortotheOvalOff~cewas ,

9 cracked.

0 Before Sugant Williams could tell me any more

.I about this issue. I told him pretty much that I didn’t want

2 ~~~sit~~~I~k~~~~~1

3 counsel.

:4 AJUROR: obthisisrsartly.

!s THEWITNES: YeSsir.

n__- A&-. m___ I* rage 4~ - rage x

Diversified Rmorting Services. Inc. (202) 296-2929
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3367

““ITED STATES DISTRICT COURT

FOR THE CISTRICT OF COLOUBIA

GRAND .,“RY PAOC!ZEDIY~ :

CrlndJuryRocmNo.3

United States District Court

Tuesday, Auqwt II, 1998

0s seprenber 19, 1991, -cinq at 4:18 p.m.. before:

1

1

IVUIT ANNE YIRzll

EmmAD J. PACE

rusoci.t* 1ndmpendent c0unwa1

1

Office of Inde~nt Counsel

1001 ~~nnsylv~a Avw~ue, N.Y.

1

suit* 490 NOEtlI

**shinqton, D.C. 20004 1

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I Page2,

PROCEEDING S

wbgeupon?

JEFFREY JAMES PURDIE

wascaUedasawitnessmd,aft.erhavingbeenftiduly

sworn by the Forepemm of the Grand Jury, was examined antd

testifii as follows:

EXAMINATION .

BY MS. WIRTH:

Q Captain Purdie, do you remember your rights and

1 reqonsibilities as a witness in the grand jury as they were 11

1 explained to you the last time you appeared? 1

1 A Yes, I believe I do. 1

1 Q Okay. And you m&stand that you’ve taken an oath 1

1 totellt&truthtoday,comct? 1,

1 A Yes, ma’am. 1.

1 Q Okay. Can you tell the gand jury wbetbcr you have 1

1 everbeeninvititoadittnfzintberesideoce? 1’

1 A when you say “the tesirknce” -- 1,

1 Q OftheWhiteHouse. I!

2 A 1 have been invited to sod fimctions as weu 21

2 as other captains at tbe White House, meaning the Christmas 2

2 party. Its’ called the zkczt Service cbktmas party. 2:

2 Butasfarasintheprivatcresidence,meaningthesecond 2.

2 floor, no, ma’am. I have not. How-, I have heard those 2,

2 2.

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In re: Grand Jury proceedings

1

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Pagem August 11, I*

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Q Soyou’venevub&ninvititoadinnerinUc

rsidencc of tbz white House?

A The private *cc, no, ma’am.

Q Okay. m you say a Secret Sea-vice Christmas

function, what is that?

A TheyhaveapartyforSecn%Servicewhaethcy

also invite some White House staff and military. Last year.

Ibelimitwasabout300to500pmple,somewhaeinthat

area. poz~ple that arc invited. It’s a Chrisbnas reception.

Youcomcin - it’s just like any social function at tk

White House. Thq give you a numbs and you get your picture

ti with tht President and you get hors d’ocums and

bevaags.

Q Okay. And Fiat is not in the rcsidcncc, that’s in

tbcmainpart?

A Thatwouldbemthcgroundfloororthcstate

floor, which m consickzd tk public rooms of tk White

House.

Q Okay. Aod did you attend such a Christmas functia~

in DeCunber of 1997?

A Ycs,Ih&cveIdid.

Q Okay. And had you attended one like that

previously?

A Yes,ma’am.

Page 4

A TberemaybavebeenoneyearIdidn’tgobecauscof

my wife being p-t, but every year tbat I’ve been

invited -- all captains in the uniform division and above are

invited. Excuse me. All captains at the White House are

invited.

Q Allright. Andothert.hanthe&cretService

Christmas party, have you ever been to any other parks in

tbe White House?

A Not when I wasn’t working. No, ma’am.

Q Okay. Okay. Otberthantheconversationthat

you’ve testifii about previously that you bad witb the

Preskknt on tk day of the incident --

A Yes,ma’am.

Q Approximately Decembez 6,1997, when the President

saidsomethingtoyoutotheeffectof-somethingabout

discretion?

A Ibe word “disaetion” was used. Yes, ma’am.

Q use your discr&m. other than that ecmversation,

have you bad any o&z umversations with the President aboul

the incideot at tbe northwest gate?

A No, ma’am.

MS. WIRTI-Iz Okay. We’re going to ask you to step

outside for just a mommt.

THEWlTNEs: okay.

MS. WIRTH: Thanks.

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