1263 

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

- 1 - 

OFFICE OF THE INDEPENDENT COUNSEL 

BRYAN LEE HALL, white, male, date of birth M 

_, Officer, United States Secret Service (USSS), Uniformed 

Division, was interviewed at the Office of the Independent 

Counsel (OIC), 

20004. 

1001 Pennsylvania Avenue, NW, Washington, DC, 

Present for the interview were Associate Independent 

Counsel MARY ANNE WIRTH, AIC, MICHAEL TRAVERS, Department of 

Justice (DOJ) Attorneys DAVE ANDERSON and ANNE WEISMANN. HALL 

was interviewed under the terms of an agreement between the OIC 

and the DOJ. After being apprised of the official identities of 

the interviewers and the nature of the interview, HALL provided 

the following information: 

HALL has been employed by the USSS since July of 1995. 

HALL was unassigned at the White House for the first two years of 

his employment. In approximately August of 1997, HALL was 

assigned to the Northwest gate of the White House. 

HALL advised the first time he saw MONICA LEWINSKY was 

in the Summer of 1997. HALL was working the Northwest gate and 

LEWINSKY came to the gate. HALL did not know who she was at the 

time. HALL had heard rumors about an intern from the East Wing 

being caught in a compromising position with the President and 

being transferred out of the White House. HALL did not associate 

that incident with LEWINSKY. 

BETTY CURRIE came down to meet LEWINSKY 

HALL believes Officer DAVE LEVINE was also at the 

time. HALL does not know whether LEWINSKY waited 

if LEWINSKY called CURRIE. HALL thinks LEWINSKY 

some sort of bag with handles. 

at the gate. 

gate at the 

for CURRIE or 

gave CURRIE 

HALL advised he could not hear the conversation between 

CURRIE and LEWINSKY. HALL did not speak to either LEWINSKY or 

CURRIE on this occasion. HALL knew who CURRIE was at the time. 

HALL does not recall CURRIE's attitude during this exchange. 

HALL advised that the fact that CURRIE came down to the Northwest 

gate made this incident stick out in his mind. 

HALL recalls another time when he saw LEWINSKY at the 

White House. HALL advised that during the first two weeks of 

Investigation on 05/21/98 at Washington, DC File # 29D-OIC-LR-35063 
1264 

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

29D-OIC-LR-35063 

Continuation of OIC-302 of 

BKYAN LEE HALL On V’ Page I 

December of 1997, on a Saturday at approximately 1O:OO a.m., he 

and Officer NIEDZWIECKI (phonetic) were on duty at the Northwest 

gate. LEWINSKY showed up and advised she had a gift for the 

President and BETTY CURRIE. 

LEWINSKY asked if her name was in the WAVES computer, 

but HALL checked LEWINSKY's name and advised she had no 

appointment. LEWINSKY attempted to call CURRIE on the telephone. 

HALL advised he called the West Wing post and asked MIKE TYLER if 

TYLER had seen CURRIE. TYLER told HALL that he had not seen 

CURRIE. 

HALL advised it was very cold on this particular day 

and he was not too busy, so he allowed LEWINSKY to sit in the 

trailer with him at the Northwest gate. HALL advised he and 

LEWINSKY had a casual conversation and the subject of LEWINSKY 

being a former East Wing employee came up. 

handles. 

HALL advised that LEWINSKY had one or two bags with 

HALL described the packages as gift bags and advised 

they may have been red. During HALL's conversation, he mentioned 

that BETTY CURRIE was probably busy. 

HALL advised the interviewers that twenty minutes prior 

to LEWINSKY's arrival, HALL had cleared a group of five or six 

people in to see CURRIE. One of the people in that group, who 

came about five minutes after the other members of the group, was 

ELEANOR MONDALE. HALL advised he had cleared MONDALE in on 

another occasion. 

HALL told LEWINSKY that CURRIE had a few people 

visiting her, including MONDALE, and maybe CURRIE was giving a 

tour. HALL advised that LEWINSKY did not react in any way to 

HALL's comment about MONDALE. LEWINSKY was not upset and advised 

HALL that she would try to stop by later. Before she left, 

LEWINSKY asked HALL if the President was in the Oval Office and 

HALL told her that the President had just moved there. HALL 

advised it was not uncommon to tell tour groups when the 

President is in the Oval Office. 

A few minutes after LEWINSKY left, Officer CHINERY from 

the E-4 post called and asked who "pissed BETTY CURRIE off." 

HALL was on a break at the time of CHINERY's call, but Sergeant 

WILLIAMS called and HALL returned to the Northwest gate. 

WILLIAMS asked HALL what he said and HALL advised WILLIAMS the 

same things he has said in this interview. 
1265 

OK-30Za (Rev. 8-19-94) 

29D-OIC-LR-35063 

Continuation of OK-302 of 

J5KYA.N LEE HALL * On us/’ Paee J 

WILLIAMS said he was going to speak to CURRIE. 

Sometime later, WILLIAMS and Captain PURDIE came back to the 

Northwest gate and advised HALL not to speak to anyone about the 

incident. HALL advised that WILLIAMS spoke to CURRIE. HALL 

advised the President may have been present also. WILLIAMS said 

that CURRIE did not have a problem with the incident. 

The DOJ attorneys advised there may be a Presidential 

Communications privilege on what PURDIE and WILLIAMS told HALL 

about their conversations with CURRIE. 

HALL later had an additional conversation with WILLIAMS 

about these events. The DOJ attorneys claimed a Presidential 

Communications privilege on these conversations, as well. 

HALL advised the only person he told about this 

incident was his wife. HALL advised that the day after the 

incident, while at roll call, someone made an offhanded remark 

about the incident and HALL denied that it happened. 

HALL advised that he never told LEWINSKY that she had 

to take a number or to wait in line. HALL advised that he never 

saw LEWINSKY again. HALL advised that he heard a rumor that 

LEWINSKY got into the White House later on the day of the 

incident. 

HALL advised he was somewhat surprised when the news 

broke in January of 1998 about LEWINSKY. 

HALL heard numerous rumors about LEWINSKY and the 

President, but he is not sure from whom he heard them. HALL 

heard that LEWINSKY had been to the Southwest gate on several 

occasions. HALL heard LEWINSKY and the President were involved 

in a relationship. 

HALL may have heard or read about a White House steward 

and LEWINSKY. HALL overheard that a White House steward 

supposedly saw LEWINSKY and the President, but HALL is not sure 

who said this. 

HALL does not know JAMIE SCHWARTZ. HALL heard there 

was an access list to the White House. 
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Inle: GrmdJuryProceedingr MIllti-P~N July 23.1998 

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1 PROCEEDINGS 

2 Wbzreupon. 

3 BRLAN HALL 

4 wascalledasewitncssanbafterhavingbarnf~~ 

5 sworn by tbc Foreperson of tbc Gmnd Jury, was uaminai and 

6 testified as follows: 

7 EXAMINATION 

8 MR. WXENBERG: Let rhc record rcfkzt tk witnrss 

9 hascntauJrhcgmdjutyroom. 

0 Madam Foreperson. we have a quorum? 

1 THE FOREPERSON: Yes, wc do. 

2 MR. WISENBERG: Any unauthorized paxau prsent? 

3 THE FOREPERSON: llnx IVC none. 

4 MR. WISENBERG: Thnk you. 

5 BY MR. WISENBERG: 

6 Q Couldyoustatcyournamcfortbcrccml.pbzsc? 

7 A Brian Hall. 

8 Q And it’s H--l-l? 

9 A Yes.sir. 

0 Q All right. MynamcisSol Wiikrg. I’mm 

I atmrncy with tbc Off& of tk hkpmcht Counsel. To my 

2 kftish4aryAnncWir&,whoisakoansI!orncyfortk 

.3 Officcof Indcpcndhrt Cnun&. Thisistbc~juryeoun 

4 ‘ rcportuandtb~tbcladicsandpentkmmofthe~ 

15 jury. 

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‘IhisisafahalgrandjuryimpanclcdbyaUmtcd 

Stares district court judge to invest&ate, among other 

things,whetherornotartainpcoplemayhavccorrLmlucd 

aimesin axmoztimwithacivilcarckno~asJoac.sv. 

Clinton. Do you e that? 

A Ye&sir. 

Q Couldyoutcllusyourtitle,plcase? 

A Im ’ an offi-. 

Q Audauoffiarwithwbtoqanizdon? 

A -nESacretSaviauniformcddivision. 

Q Okay. And it would be appropriate to refer to 

you - to call you Ofher Hall? Is that con&? 

A Ibat’sfine. 

Q Allright. I’mgoingtotcllyoualittlcbit 

beforemstanaboutyourrightsandruponsibilitiesasa 

gand jtny witness and if thae’s anything you doo’t 

llnw wily dcm’t you let us hMYw, all right? 

A okay. 

Q Fvstofall,ywdonothavctbtrighttobavtm 

aaomcyinthtgrandjuryroomiKithyou,butyouQnha~an 

attomcywtsideaudyoucanamsultwiththatatto~if 

youedto. Ihyouundueandthat? 

A Ye&sir. 

Q And do you have an attorney outside for you to 

consult with? 

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A Yes, sir. 

Q Canyoutclluswbotbatis? 

A Its ’ Locannc Turna. 

Q O?my. Tbars ’ your personal atton@ 

A Yes. 

Q Okay. -Turns? 

A hyf-. 

Q Im ’ sorry. Lcnay Turner? Okay. Is tbt 

Ltaa-y? 

A Imnot ’ sum. 

Q Okay. Also, you have a pdvilrgc against 

self-irlcrimiMtion 01 a aigtll @rIst sclf~tifln. 

Ifrmlthful Mswuloaquc&onwould~In 

incrimiMkylnhy0udm?iuwcroAasww th. You 

cansay,“I’minvoUngmyFiful&nmcJmmlrigbt. Do 

you lmda-suuld that7 

A Y6.sir. 

Q AvuybasiccxarnpkoftbatwouldbcifIask 

you “Dii you rub tk Gothn City Bank on Cktobcz 3.1966.” 

you probably w’t bcun then, but Gctobcr 3.1966. and 

youdid-youhod~robbcdhatruthful~swcrto 

tlultwuukIkp,youwouldn’tbnvcIododm~ 

A oluy. 

Q Ya, undustaad that? 

A Yer. sir. 

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Page 

I Q Andthese~qtionsthatwaskofvirtuaIlyof 

2 all grand jury witnesses and I’m going through them, but it’s 

3 important that you indicatc$ you know, whetbcr of not you 

4 understand what I’m saying. 

5 Anotherthingis,ofcowe,youtookaaoathto 

6 tcIltbetruth. Doyourmdcrstandthat? 

7 A Ys,sir. 

8 Q Doyouundasteadwhattbatmcans? lhatu.nhsyotI 

9 take a privilege on som&ing whnz you say, “I’m not going 

0 to answer,” tbat you have to butbfully answer allofour 

1 questions. You undustand that? 

2 A Yes, Sir. 

3 Q Okay. Is tbze anything about your rights and 

4 responsibilities as I’ve explained them that you don’t 

5 understand? 

6 A No, sir. 

7 Q Ifthere’srlnythingmdon’taskpropaly,tbatis, 

8 it’s not clear to you, please let us know and we’ll try to 

9 rephrase it. How’s that? 

0 A ?hat ‘ S ’ fine. 

1 MR. WISENBERG: And you might sac some other 

2 attorneys from our off& coming in and as WC pmaxd. 

3 We’ll try to keep t&Tic down to a minimum. I’m going 

4 toNmoverquestioningu,Ms.WirthandIhawtogo 

5 outside for just a m-t. 

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BY MS. WIRTH: 

Q Offar Hall, you’ve bum employed by the Saxct 

Service since 1995. Is that right? 

A Yes. 

Q And you’re. with the unifomxd division? 

A Yes. 

Q Okay. And for the fim two years of your 

employment with the &ret Service, you were assigned to the 

White Housz. ls that right? 

A That’s comzct. 

Q And in August of 1997, you were assigned to the 

northwest gate of the White House. 1s that correct? 

A 

Q 

A 

Q 

‘97? 

A 

Q 

YS. 

And is that your mt assignment? 

Yes, ma’am. 

Okay. And you’ve held it steadily since August of 

Yes. 

All right. Can you tell tbe grand jury whether you 

have ever seen Monica Ixwinsky? 

A Yes. 

Q Canyoutellusabouttkfirsttimetbatyousaw 

ha? 

A ‘Zbeexactdate,I’mnotsure. Itwasknow, but an exact date, I’m not sure. 

PUXly July 23.1998 

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Q Wasitthsmnmer of 1997? 

A Yes. I 

Q Okay. So last summer. 

A Yes. 

Q Okay. Andcanyoutelltbegmndj~wbcreyou 

wueattbetimethfltyousawher? 

A Atthcno&vcstgateatthcWhitcHws,whicbis 

located on 1600 Pcansylvania Avenue, the old no&west gate, 

I should say. 

Q Okay. And prior to that date, had you ever beard 

hcrMmc? 

A Well, I’m not swc 

Q You don’t nmcmbu? 

A No. 

Q Okay. What bappcaai that day? 

A Iwasn’tthtprimafypersoninvoived,Iwasinside 

tbcnorhvcstgatc. IfI~BettyCurrichadwmedowo 

f&n-IpresumctheWcstWin&Ijustatmouttothegate 

and I just observed an intuaction. 

Q Okay. SoButycamtdowntonnxtMonica? 

A lprcsumc,~. 

Q Okay. And,bytheway,howdoyouknowthatthis 

MonicaLhnsky? DidyoulcokatA lhavenoidca. Ijust-now,I’mthi&ngthat 

it was. I’m still not 100 wt wlc. 

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Q Okay. Soontbatday,didyouknowkrnameoo 

that day? 

A No. 

Q So are you basing your conclusion on pictws that 

youve ’ an of her and you tbink that this is the person? 

A lthinkso. Yes. 

Q Okay. All right. So you said that Betty Curie 

came downstairs to the northwest gate and had some 

intcfactiun with tbis jluson who you think was MO&a 

lxwinsky. 

A Yes. 

Q Okay. Andwhat-didyouovcrhmranyofrhcir 

CavasatiOn? 

A 

Q 

A 

Q 

A 

Q 

A 

itan. 

Q 

A 

Q 

A 

No. 

Didyousutkmexcbaugeanythiug? 

Ibey@=ch=J&Msamcthing. ‘

What was it? 

I don’t know. 

Who gave what to whom? 

ItlookallikcMs.Lcwin&yhaa&dMrs.Curriean 

Okay. Andwhatdiditlooklikc? 

1 can’t nzau. 

Okay. Wasitinsomcsortofcontaincx7 

Ithinkitwasinabag,butI’mnot lOOperant 

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inrc: GmadhpyProcbodings 

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1 sure. 

2 Q Okay. Hmvbigwastkbag? 

3 A Wdlfmmwfrat~ted,itwasparscdkrwrmthc 

4 p*mdtkgatLP~pproximntdy-mayksix~widc 

S soslmlaegmtktwidfbIgllcss. 

6 Q IMitbokI.ikeastqpinghgorgiftba&s 

7 plasticbeg? 

8 A Indycdtrcd,tobchcst Imnot~ ’

9 Q Didrkbagbav~bandlrs? 

0 A Im ’ sot sure. 

1 QJJQYOU rurunberwhmyouwacintuvinvcdbyanPB1 

2 agmtandotberstranrbeclfIiioftkIt&pmdmtcumsel 

3 ihcbuIiogtnc? 

4 A YK. 

S Q OLoay. Andontbatday,doyottn!mcmbu8%q 

6 qbodythatMs.L&nskygWMs.CatnieontbatdAtesomc 

7 sottofbagwitbbandks? 

8 A Imayhavc.butI‘mjust#ayingtodayIdon’t 

9 XeallwhN- 

:O Q Okay. Allrigh~ Butywovahcanlao 

1 cQtl~~-~tbatday. 

.2 A No. 

3 Q Andh4s.Lcwin&ydidnotgoinsidewitbMs.Cunic? 

4 A No. 

S Q Insi& tk white House? And Ms. Curric kfi at 

Page I(1 

I that point and went hack inside the White HOW? 

2 A yet. 

3 Q Okay. And where did Ms. Lvinsky go? 

4 A ~haVt?nOidea. 

5 Q Did six leave? 

6 A Yes. 

7 Q Yes? Okay. All right When was the next time you 

8 saw this person who you’ve identified as Monica Ixwinsky? 

9 A ItwzSinIkcemkr. 

0 Q Okay. Of I997? 

1 A Yes. 

2 Q And was that also at the northwest gate? 

3 A It’satthccurrentnorthWstgate,whichismaybc 

4 a few fat diff-. It’s in a traiIcr now. 

5 Q Okay. A few feet diffemnt from where it was tk 

6 previous summer7 

1 A Yes. 

8 Q All right. And do you remember what day of the 

9 weekitwas? 

0 A 1 helicve it was a Saturday. 

1 Q Okay. Do you remember whether it was tk fim 

2 Saturday in Deeember? 

3 A Ithinkitwas,butI’mnot100percuttsu~. 

4 Q Okay. Tcilthtgtandjutywhathappmed. 

5 A bi~.Lcwinskyom~Upt~rhcnOrthWcSt~and~ 

P81zcrn Juiv 23.1998 

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dm’tranmrbaifIpickniupmephoncor~ttothcdoor. 

I’mnots~butskbadstnadskhc~for 

Ms.Curric. AodIask4Mr.Lovinckyifskwasckuuim 

andsks8idskdidn’ttbinksn. 

soItookInIDalldwclmvcrcompuKrsystcm, 

tW’rbowyeucbecktoseeifscm&ody’sbeonckarcdin. 

it’scalkdttc’InulraaMmeaadsk 

wuar’tcbvedin,roIrmitbyherfirstiaitLlofba 

~namanddsqofbLthMdrb:stiUdidn’tcomcup~ 

Ckdd. 

Q Wknyousay”chtui.“youtncantbatskhdA No~ppoiuttnm~ 

Q -&mcctokittdutdaytithan~ppointtnatt 

A Yes. 

Q Okay. 4-b. 

A Yes. 

Q Allright. tiwbtbppdncxtthat? 

A Sksmrdthatskdkia’tbckveshewasclcared 

mcaatin. Sksaidsk’dgoakadandkapusingtkbousc 

phmctofryrmdgecckarcdiu. AnhI’mnotsumif-I 

bd+cit~4ttbnttimcwrrrwfra1wu;tzyingtocaIl 

offiiTykr~tsideof&ny’soffi ; 

tosmifBcttywasamu&justmsarifwccouldf~aut 

ifshccoutduancoutorwhat~goingtohapparkcsuocrhc [ 

lbudgiftsforkr. 1 

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1 Q Okay. That’s OfIii Michxl TyIer? I 

! 

2 A Yes. 

3 Q”‘-)t ? 

4 A 

5 Q ? 

6 A Yes. i 

7 Q What is it? 

8 All b 

9 QC 

0 A Yes. 

1 Q Okay. Okay. Whenyatsaidsheusedthchouse ; 

2 phone,wasthataphoneinsideyourtraiIef? 

3 A No, it’s outside the traiIer, outside the door. I 

4 It’EhangingIikeonthetenlpemlyfenee. 

S 

6 

Q DoyouhtowwhcthcrshevvasahIetoreaehanyho@? / 

A Idon’t know. 

7 Q Did she ever teII you? 

8 A No. 

9 Q What happened next? 

0 A FromwhatIrrmanba,itwasacoldaday,sosince’ 

1 shewasthetetoseeMs.Currie,Iaskedherifshewantedto 

2 stepin. Shesaidsun,so&cmtein3 Q i&thet&zr? 

4 A Yes. 

5 Q Did she sit down? 

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A Idont ’ remember. I don’t know if she was sitting 

or standing. I’m not sure. 

Q Sowhathappcnedthcn? 

A wejustcngagadin~tak 

Q Youandsk? 

A Yes. 

Q hyou-krar@iqyoutalkaiabout? 

A ShewassaymgthatBcttywasprobablybusyandI 

said. you know. I think she was because maybe previously. 

five, ten minutes before that had cleared in a group to go up 

to Ms. Cunic’s office I stated that one of the people was 

Eleanor Mondale and she said, “Oh? Okay.” 

Q I’m sorry. So you told Monica L&n&y that Betty 

curric was probably busy? 

A Yes. Maybegivingatourorsomethingofthat 

sort. 

Q ,%ndwastbisbecauseMonicatoldyoushecouldn’t 

teach Betty Currie? 

A No,Iwasjust asmmingtbat’swbathadhappened. 

Ijustremcmbaclcaringthcptopleia,soIwasjustkindof 

I agreeingthatsheprobablywasbusyatthetime. 

2 Q Okay. And you told Monica Lcwin&y that ox of tk 

2 peoplethatKasinthcgroupthatBmyC~mightbe 

4 giving a tour to was Eleanor Mondale? 

5 A Yes. 

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Q Okay. And how did you know tbat? 

A Ihadclearedthegroupinandthat’sthenamethat 

stuck auf being that she’s the former via president’s 

daughter, it just stuck in my mind. 

Q Had you ever men Eleanor Mondale before that day? 

A Yes. 

Q And so you knew her? 

A Yes 

Q Okay. Allright. So wknyousaidtbatto 

Ms. L&n&y. did she. have a reaction? 

A No. Well, she said, “Oh? Okay.” I mean - 

Q Did she ask you any questions about the Resicknt’s 

whemabouts? 

A Yes. ItcameovertberadiothatBaglewasgoing 

totheOvalOfftiaanditwasafm~utaaftatheradio 

trafl?ccameoversheaskedif-I’mnotexactly-tbe 

exactwordsIdon’tlrnowifshcsaid.“Hashcmadtittothc 

oval?” Or “Is he in the oval?” And I just said, “Yes.” 

Q Andyousaidamomentagothattheradiotid 

“Eagle.” That refers to the President? 

A Mm+mm. 

Q Andwassbeinaposition.Monic+tooverheartbat 

radio tmmmission? 

A She may. 1 don’t know. Sbe was right in front of 

it, so -- 

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Q Soskaskedyouifkmackittotheovalandyol: 

said what? 

A I’mnotsumoftkexactqustionsheasked,shc 

eitkrsaid”Haskma&it? Or”Iskintkoval?” And 

Ijust~~~~baztuscIbtardtkmciIlltimgoinginxc 

tkoval. 

Q Didsbebaveareactiontothat? 

A No. 

Q -happcntd*? 

A OD: thing I forgot to mention, that during the 

converratioashthadtoldmcthat,youImow,shthadwaked 

attheWbiteHo~intkEastWingandsbewasanin~. 

ButaftcrthaSsbcjustsaidwelLrbcwwldtrybacklatc 

rmdsbtpi&dhcrtbitlgstlpMldIcft. 

Q Whatdidshelmvewithberthatday? 

A Ibelieve-wI.ratIrecaUwastwobags. 

Q Okay. Andhadsbetoldyouatsmnepointwbatans 

intbebagsorwhattbeywcrr? Didshetellyoutbeywue 

presents for anyone? 

A Skjustsaidtbeywueforh&.Cunie. 

Q tishehadsaidthatearlierbninyour 

2 conversatimwithhu? 

3 A Yts. 

4 Q Okay. Anddidnotmzntionthcwordgifts? Skdid 

5 notmmtioatkwordgihs? 

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1 A We&sbesaidtbeywuegi.tisforMs.Currie. 

2 Q Okay. Andcouldyouseewrappedpackagsintbc 

3 bags? Did you look? 

4 A I don’t recall. I’m not sure what it was. 

5 Q Sotoyourlmowledge,tkn,nostepsweretakcnat 

6 thatpointtogetherinthroughtbe 

7 A Nottomyknowlodge. 

8 Q DidBettyCurrieevercalldowntoyourpostat 

9 au? 

D A kttykr&m. * 

1 Q HowsoonaftcryoutoIdh4onicatlmttkF’msidmt 

2 badma&itintotbeOvalOfli~didshelmve? 

3 A Approxhtcly he to tea minutes. 

4 Q SoskwaitcdarrnmdaIittlcbitmae? 

5 A Afcwminutcs,ys 

6 Q hddida+hinghpparduringtbattime? Youbnw 

7 toE0!3wvErbally. 

B A No. I’m sony. 

? Q npingthattim;didyoubavcanyumvcrsation 

1 wirhMrmilaLewinskyttlatyouluncmkr? 

I A Nottbcu1twaU. 

2 Q Allright. Cauywtelltkgrandjuryaboutwkt 

5 happatal~Mcmhl&? Howdiditoccw? Didskuy 

4 an-? Didskjustaardupandlcavc? I 

5 A Sksaidskwouldjusttrykcklatcrandlcft. I 

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Q Andsbetookbcrthingswithbcr? 1 A Well,thcnIgotacall,Ibclievcituaso~the 

A Yes. 2 t7uiio,tolespondbacktothcnorthwtsrgatc. 

Q Allright Andwbat’stkaextthingthat 3 Q Fmnlmcb? 

hap@? 4 A YCS. 

A I’mnotslacwtrattyptoftbncframcwcntby,butI 5 Q Okay. Aud you did that? 

gotacallfrumofcccrCbinery. Ifo!gcttbecxact 6 A I&n-hmm 

dihguc,butitwastotbcdfccttbtBcny~upSad 7 Q Andwbmyou8otthtn,wbodidyOusU? 

mrSWOdQillgWbtwaSS8id. 8 A ScrgmntWilliamwasupthcrrandkbadaskedme 

Q okay. oniar chinay Lzalkl you? 9 whathadwlentanandthat’swhmItoldhimwimthappmed. 

A YES. 1 0 Q whatdidyoutcI~%@eantWilliams? 

Q Okay. And k said that &ay Curtic was upset? 1 

A Yts. 1 

Q Did you know Betty Cmie? Had you ever met ber? 1 

A I’vcnevumctberpmonally,butIkmwwbosbe 1 

is. 1 

Q Youhadmzllbct? 1 

A YeS. 1 

Q Okay. And Off&r Chinery said that Betty Curie I 

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wasupset,shcumtitoknowwhatwassaid Saidtowho? 

A Ihavcnoidca. Idon’trecaIltheentirr 

comers&on. but - I meau, it was to that effect of what 

happcacdIgutss. 

Q Didyouhavethcscmethatyouwenzbcingasked 

about what had b&n said to Monica Lewinsky at that point? 

A Yes. 

l A JustwbatImldyouwfrathappenai. 

2 6 U’hicbwaswhat? Tcllusagain. 

3 A IbathfaaiCaCmC~tO~gatc-C~~~LXmc. ‘

4 Ms_Lwins&,sayingthatskbaditcmsforMs.Cunicsm& 

5 you~w,shcwasn’t~inendsoshtsaid~would 

6c5mcbackIata. 

7 Q Okay. AnddidyoutcllhimthatyouhadtoId 

8 Monicathattbatwasa~upupintbtOval~aandthat 

9 BcuyCurriemigfitkgivingatour? 

0 A Yes. 

1 Q Anddidyoutcllhimthatoneoftbepcopleinthe 

2 gmupwasELnorMondaleandthatyouhadtoldtbatto 

3MonicaLewinsLy? 

4 A Yes. 

5 Q Didyoualsotellhim,king~tWii 

Page zc 

1 tbatMmicaLvinskybadaskcdyouwk&crtkRaidmtkd 

2 reached tk Oval Office md you rapon&d that k kd? 

3 A Yes. 

4 Q Okay. DidSageanrWilliamsspcaktuanymcdsc 

5 besicksyou? 

6 A Idao’tzuall. 

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Q How did you know that, that it was with respect to 

her? 

A Well, I really didn’t, but I - you how, I don’t 

rememberifheaskedwhatwassaidtohcrorto~tcffccf 

thatIgottkidca,butIjusthadto~dhimthatIwastbe 

onethatwasdcalingwithMs.Lwimkyandtbatwasit. He 

said okay. 

Q Did you tell him what had b&n said? 

A No. 

Q Why was that? 

A There was no need to. 

Q Okay. And did he tell you that Betty was upset? 

A Yes. 

Q Did you have any idea what that was about? You 

have ta answer verbally. 

A No. 

Q Okay. WbatdidOffiarChinnysaytoyouthcn? 

A Well, we hung up. 

Q Okay. Tkn what happened? 

A Iwenttoeatinthe-notthecafeteria,butour 

down room in the Old Executive OfIia Building. 

Q And then what happened? Did you kar anythin 

about it while you welt down that? 

A No. 

Q Didyoucomebacktoyourpast? 

7 Q DidSugeanrWilhnscvutcllyou-wdldidk 

8 tcUyouwbykwasaskingabouttbisincidmt7 

9 A Notattbcthncno. 

0 Q DidkteUyoutbatanyoncwasupsctaboutit? 

1 A Not at tkt time. 

2 Q Diik~yousnytbiqlikcEommcw. couldk 

3 fvedovu?&aaclyth@likctbat? 

4 A Notattbsttimcno. 

5 Q AJlri8ht. Afmyourpdrc~&qc-.otWGms. 

6 didyouqaktomybodydseabolltthis? 

7 A WdlCqhnRudicwlpulkd~~~ 

8 thot’s-IQo’tImow,Iacvcrml)ccdtotbemIm~afa 

9 rbybadcomcbnckdownfromtkwcstwicg. 

0 Q Okay. WdL what’s tk acxt thin8 that Lppad. 

I then. ahc7 you spoke to Sugcant Willims? 

2 A IprcsutmkwmtuptotkWestWin&butI’mnot 

3 sulc Ic&n’tknov. 

4 Q DidksaytlmtwaswlmtkwasBoiogsodo? 

5 A HcsaidkwasgoiagtogotalktoBcfty. SoDiversified Reoortinrr Services. Inc. (2021296-2929 

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Q Anddidtkxccamcatimcwknyoukardwbthis 

mnvasation with Bury Cum& bad ban? 

A Latcrontbataty.bef~mbadkftfortkday, 

Imnintohiminthemm’sroomradbejustsaid-hesaid 

~kweotuptoBcoy’sofficc~t-ywkaow,kbad 

mhdtohaandcxpbiredwhstbgcacd. Igussthc 

P&dent was tkrc and bxl stated tbt k waned tk off~cu 

fti. 

Q And Sagcant Williams told pu tbat or Ce.pmin 

PlUdiC? 

A ~tu’ii. 

Q Okay. LamcgathisstG$~~ -‘Wii 

camccywrwila,yougats~~comebsckfromluncb 

youwmttothceaikr~yourcpoficdmcrr.andyoubsda 

cclnvcMtion with !3qumt Williams wbae you rchod to him 

what you stir&l to today, conut? 

A hh-hmm. Yes. 

Q TkaScqcantWihnskfttogot&to&tty 

Curric. Hctoldyou’l’mgoingtotalktoBcttyCurric” 

comet? 

A Ya. 

Q Wbatisthtncxtthingthatlmppcnad? Wasityour 

conversation with Sagant Williams what k told you about 

what happened with Bay Cti or did smnetbing &c happen? 

A I’m not exactly sfpc. 

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Page 22 

Q Did you ever xx Captain Purdie that day? 

A Yes. 

Q Did you see Captain Purdie before you saw -1 

Williams in the men’s room? 

A Yes. 

Q Okay. What happenedwith Captain Purdie? Where 

did you suz him? 

A Captain Purdie and Sergeant Williams came from 

whcrcvertbeywere.I’mnotsurewheretheywere,andjust 

talked to me in. the sergeant’s office at the trailer and said 

that, you know, ever@ng was fine and not to worry. That’s 

2 just basically the gist that I recall. 

3 Q WasthisthefuStimeyoubadseenCaptainPurdie 

4 thatday? 

5 A I believe so. 

6 Q Who spoke to you? Which of the two? 

7 A WeII,tbeywertbothtbere. 

9 Q Didcitherofthemindieatetoyouthattbcyhad 

9 bcenuptospeaktoBettyCurrie? 

1 A Ibeiieveso. Yes. Yes. 

I Q And did either of them tell you whar at that time, 

2 while you were in the tiler, what that mvcrsation with 

3 Betty Currie had ban, any part of it? 

1 A Idon’trecall. I’m notsure. 

5 Q You said a moment ago that they told you that 

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evqhing was going to be okay, not to worry about it? 

A Yes. 

Q Uptothispoin~badyoubeardthatsomeonemight 

get fd over this event? Had that nrtcrcd the 

conversation, any of the convcMtions you had up until that 

point? 

A NottbatImaU. 

Q Okay. So you’re hearing everyhing’s going to be 

okay at this point frotn Captain Put-die and Sergeant Williams 

@It? 

A Yes. 

Q Okay. Wbywueyoubeingtoldtbateve@hingwas 

goingtobedcay? 

A I’mnotsurt. 

Q Didyouhavcanyrtafoatothinkotbawix? 

A No. 

Q Uptabtpoint_youknewthatBettyCutriewas 

upset, axrcct? About this. 

A OffiarChinerybadstatedt&at. 

Q Iiadtoldyouthat. 

A Yes. 

Q Otb~tbanOfIicerCbinerytclIingyouthatBetty 

Curriewasups&didanybodyektellyoutbtEkttyCurric 

4 wasupsuuptothatpoint? 

5 A Idon’tmzall. No. 

Page 2+ 

1 Q Did anybody up until that point tnattion the 

2 President’s name in txnmection with any of this as being 

3 involved or having said anything? 

4 A Idon’tnxall. 

5 Q Okay. Otherthanbeingtoldthatcverything~ 

6 goingtobeokay,istbereanythingclseyou zunemberabout 

7 that eonvusation with Captain Purdic and Sagcant Williams 

8 A Notatthistime. 

9 Q Allright. Whatbappaxdnext? 

0 A we&thatwasaftcrIraninto~tWilliams 

1 intbenxn’sroom. 

2 Q WbendidyounmintoSageantW~intbe 

3 men’sroom? 

4 A I’mmtmrcexaetIywhattimeitwas. 

5 Q Itwastbatsameday? 

6 A Exactly. Yes. 

7 Q AnditwasafteryourcuovasationittdtetraiIer 

8 with Captain Purdie and Sergeant Williums? 

9 A Yes. 

D Q Wasitthenextthingthatyouremembuhappenittg 

I in relation to this incident? 

2 A Yes. 

3 Q Okay. Now, tell us about that. what was tk 

4 maa’s room in relation to your tier? 

5 A It’s in the Old Jkcutivc Office BuiIding maybe 

Page21 -Page24 

Diversified Reporting Services. Inc. (2021296-2929 
Inn: GrmdJury~~ M&i-PSgCN 

mF= 

I 50 fat away. 

2 Q Tbat’stkmm’sroomyou~lyuscwh~nyou’m 

3 on duty7 

4 A Yes. 

5 Q AadyousawSageantW~thaqyousaid 

6 A Yes. 

7 Q Whatdidhetcllyou? 

8 A &stakdth~at~k~kwaS~ptk~th&yOU 

9 know. tk R&&It had jut satad be ward tbc Offlim 

1 0 fucd. 

1 1 Q Okay. Did Sergeant Williams tell you that bc had 

1 2 sxnButycurrie? 

1 3 A Ycs,~thinkS~. 

1 4 Q Andwbmyousay”upthac”youmcanIhe~ 

1 5 Offia? 

1 6 A Imnotexactlysurr:iftbcy~inthcOV~Or ’

I 7 Ms. Cuuie’s offia. I don’t know. 

1 8 Q SoSqeaotWilliamstoldyouthathehadqen 

I 9 Betty Cunie. Yes? 

2 :0 A Yes. 

2 !I Q Okay. Didhetellyouthatkhadalsosrmthe 

2 12 Resident, physically? 

2 !3 A Yes. 

2 14 Q Okay. Are you cmain ofthat? 

2 !5 A YCS. 

Page 26 

Q And tell us to tk best of your memory what 

Sergeant Williams told you about that. 

A That’s -- 

Q Did he tell you where be had sun the Resident? 

A Idon’tknowifitwasintheovalorifitwasin 

actually Ms. Currie’s offta, but in that general ama. I’m 

just presuming. And all he had said was that the President 

stated he wanted the Offlar f& 

Q Okay. Did he say “‘Ik Resident told me he wanted 

I the Offlar fired”? 

I A Im ’ not - Im ’ not SUrc. 

1 Q Did he say “Betty Curric told me the President 

I wants this officer fired’? 

I A I’mnotsumhowitwasstated. Iwasn’tthem. 

1 Q Okay. Well, how did you get the impression that 

I the President spoke dim&y to Sergeant Williams? 

I A -hatswbat% ’ @XOtWilliamsh?dtid.WaShChad ‘

1 made that statement. 

1 Q Thatthebcsidcntspokctohim? 

2 A Yes. 

2 Q Did Sergeant Williams tell you what he had said to 

2 the President when the Resident said that? 

2 A Idant ’ rdcall. - 

2 Q Well, this was after you wue told that everything 

: 

Page 27 

I thatCa@inFWdie2 A Yes. lt was btcr. After that. Yes. 

3 Q Okay. S.owhatlnippenedinhetweenther.milaand 

4 tkbathomtha5 A kiell.I ’ mnotSaWWtat-tbiswassaid,~think, ’

6 earlicr~dI’mnotsurr-II--_yhehadmadcthc 

7 statmaeintbercsmam. I’mnotsum. 

8 MR. WISENTERG: Do you mind if I bun in? 

9 MS. WIRTH: No. 

0 BY MR. WISENBERG: 

1 Q Whenyousaythismi&thavebamsaidcarhcr,you 

2meanthe mt that tk Pmsidcnt said. 

3 A hactly. 

4 Q Sowoulditbe-soitwaskindoflikeahistory *’ 

5 ofwhathadhappeoalt.batmoming,thisiswhathesaid 

6 carlicrcm,aloagthosehcs? 

7 A Wcll,intktmilcr,nothingwassaidabouttkt 

8 andthatwasbeforetbemstroom. 

9 Q Wt. 

0 A I’mjustsayingI’mnotsiucwhyitwassaidlater. 

J Idon’tkmnv. I’mnot sum. 

2 Q Right. But what I’m - I know you’re saying that 

3 itwasn’tsaiduntiltheres&oom andIknowwe’reheingvcry 

4 detailed, but we want to get your absolute best rceollstioo 

5 onthis. 

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!5 wasgoingtokdlright,right? Inthctraiier. Yousaid 

Page 2s 

t AsIuodemtandit,Iundthercsuoom 

2 incident occurred after the trailer incident. but am you 

3 telling us that in that restroom incident that Sergeant 

4 Williams is telling you the stataxntaboutthePmsi&nt 

5 wanting you fved was something that the President had said 

6 carlierintheday,befomthingstumedouttobeokay? 

7 A IprCSUmc, ’ yeS. YCS. 

8 MR. WISENBERG: Okay. 

9 BY MS. %‘IR’IH: 

0 Q SoItakeit,tba&%geantWiiamswas,and 

I comctmeifI’mmon&sayinginefftctroyoU’Bay,this 

2 is bow bad it was, but it’s all taken cam of.” Was it 

3 somethingIiithat? Imean,whywasheteuirIgyouthis? 

4 A I’mnotsum. Ibavenoidea 

5 Q ButdidkstilIcxmeytkimpc.sGontoyoutkI 

6 thingsmrcokay? 

7 A Yes. 

8 Q Eveorhoughthathadbansaidearlierbythe 

9 Pmsident? 

0 A Yes. 

1 Q Did Sergeant Williams tell you anything about tht 

2 Rmsidcnt’s demeanor when he spoke to Williams? 

3 A Notthatlmcall. No. 

4 Q DidSergmtntWilliamseverteUyouwhether5 ScrBQntWilliamsatsomcpointtoldyoukhadspdrenb 

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Page 29 

Ekny Camic. comd? He said that? 

A Yes. 

Q Anddid~tWiUiamsteIlyouanylhiqgrbour 

Bettycurrsrmanna illsprakingtohimWk¶k?Sk\ns 

upsuasOfEcer#iuqkdmldyrmtktskwar? Didyou 

evuba3ran~iikctktfmm~tWilliams? 

A Idon’td. 

Q All@& orbatban%q=ntW~~ 

youtbatbespo~totbcRsidentaodtbtRsidcntto]dbim 

tbatkwanodtbcoEiecrfnuididSerprantWisay. - 

“AndItoldhimyouknow,Qnt&thsr”ol’?bisis~~ 

shouldn’tdo&is,“cranyXbing&etbat? Didktiyou 

aoythiagtitkkdflid? 

A Idon’tklimso. No. 

Q Okay. Howdidyoufeelwbmyoubadthis 

wnvas&m with sageant Williams? waz you upset? wac 

youokny? WbardidyouIhink? 

A whcn.inthcratmom? 

Q Mm-huun. 

A Iwassk~kalmo~~tknanyth+?. 

Q Did you ask Sageaat WilIiams my qu&cms? 

A No,justkftitstthat_ 

Q Oksy. Did you ever have any e&r convusations 

witbanybodywkrc*raiscdihsttbouehfthstsolmcbody 

might k fti over this incident or tbar you might k fual 

Page 3c 

I over this incidmt? Was that ever raisd again? 

2 A 1 had just - I had mentioned something myself to 

3 Officer Tyler. I’m not sure exactly how long it was after 

4 the incident, but I had stated that myself. 

5 Q 

6 A 

7 Q 

8 A 

9 Q 

0 A 

t Q 

2 A 

.3 Q 

You told him whgt Sageant Wiiliams had told you? 

Ye% 

And is Tyicr a friend of yours? 

YeS. 

And what did Offiar Tyler say? 

I can’t R&y Iecall what his comment was. 

Did Off&r Tyler remember thar day? 

Ihavenoidea. 

All right. That day, after your wnversation with 

4 Sergeant Williamsinthebathom,didyouspaktocmybody 

.s ek? 

.6 A After&&day? 

:7 Q Yes. 

.8 A I told my immediate supcrvisr what had happened 

;9 becausesaw:things~goingaroundatthehous,soIjust 

!o told him what had happened. 

!I Q ‘Ihatverysameday? 

!2 A No. 

!3 Q I’msorry. I_ctcnebackupjustaminute. That 

!4 verysamcday,t.hisday,ttkedaythattbishappa.icd+that 

!5 Saturday, after you spoke to .Scrpnt Williams in the I: 

PllgP July 23.1998 

1 

Page31 

1 bathroom, did you speak to anybody else that day about this 

2 incident? 

3 A Onthejob? 

4 Q Yes. Let’saartthem. 

5 A No. 

6 Q No? Did anybody ever tell you anything to the 

7 effect of that you shouldnt ’ talk about this incidm~ you 

8 slmldnt ’ tc.U imybody about it? 

9 A YCS. 

10 Q Who told you that? 

11 A Ib&veCqainhrdieandSagwtWilhms. 

12 Q wEsthatdtxingtheamvcrsationintheuai1cr? 

13 A I think so. 

14 Q lh%t5day? 

IS A YS. 

16 Q Tkoncyou’vcakadytoldusabout. 

I? A YU. 

18 Q ,%.nddoyourememberwtrattbeytoldyouorwhosaid 

19 itandwhattbcysaid? 

t0 A NotreaIIy. Just-thatwasaboutit,Ithink. 

ti Q Doyoutumnhcrwhosaidit? 

u A I~~of~~~rn~~dit. 

u Q Didthcysaywhyyoushouidn’t&Uaayone? 

t4 A No. 

!5 Q Did you imdanand why you shouIda’t ?cU anyone? 

I 

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DidyouhavcanuadaJtandingofwbyyouwcrr.kingtoldoot 

todothefl 

A Ipnslmr,ya. 

Q I3cforem~totbat.mxyoubeiqorducdaot 

totelsanyone? wastktyourundC=uuKlhl&thMtbiswu 

anorderfroma %goffznotorpakabouttbis? 

orwercyoub&gadviscdnottosp5kabaatit7 

A Advised. I wmld think. 

Q Andwbiatwasyourundmtmdiqofwhyywwac 

bdngroldtktorwbyyouwar:beingadvisairrattorpesk 

about tk incidart? 

A Igucssjustsunhiagwouldgctoutabat,you 

kmw,wbatkdhappenai. I’mnotsllrcoftka.actrr8soa% 

but - 

Q Ohy. Didzaybodycumccttkdvia?ktyat 

skukIn’tqnak&asthiswitballythiqtbattiJqk4lbcca 

roldby&dRf 

A I’mnotstnr:wbatyoulnaul. 

Q Well,&dwbmusnidtbisbym.wk4kritwas 

!5ug?mtWillimaCsptainFurdicorbot&diddtbaalc 

ofthmIs3ytoyou-Don’ttalkaboutthis.Baycmicmys 

youshouldn’tpllrrbouti;“or”Ifpudoa’tELnL~bOUtit 

evqylhiogwiIlkall+&“or’TkResidmtsaysdcm’t 

talk about it” anything like tkt? 

A No. I 

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Page 3: 

1 Q No? Okay. All right. Afterthat day. then, you 

2 said that you told your commanding officer at some point, 

3 your direct supcrvism? 

4 A Yes. 

5 Q Wbowasyourdircctsupcrvisor? 

6 A Ron-. 

7 QRanwbat? 

8 A-. 

9 Q P-a-r-t-h - 

0 A ell~0-FC 

1 Q Andwhmdidyoutellhiminxzlatioototbe - 

2 incident? 

3 A Itwasprobablyatleastaweckormaybetwo. 

4 Q Whydidyouwaitaolongtotellbim? 

5 A I don’t know. 

6 Q Hadyo~.¶?enbiminbeSwum? 

7 A Yes. 

8 Q Doyouhaveanyideawhyyoucboaetbatmomentto 

9 tellhimabouti~aweekortwolater? 

0 A Hebad-Idoo’tknow-Iguessnzmors,kbad 

1 keobearingthings,thatthuewasanincidentattkgate 

2 andkwaswantingtokaowifitwasdrrringhisshifSthat 

3 waykcouldkprepaxdifsomething-but4 Q So he brought it up. 

5 A Yes. 

Page 34 

1 Q Was he on duty that day? 

2 A I don’t think so. 

3 MR. WISENBERG: Wbat day? 

4 MS. WIRTH: I’m sorry. 

5 BY MS. WIRTH: 

6 Q Was he on duty tk day of this incident? On that 

7 Saturday at the nonhwest gate? 

8 A No. I don’t think so, but I’m not SIX. 

9 Q All right. Okay. Did you ever speak to Sergeant 

D Williams again about this incident after tk date of tk 

1 incident? 

2 A IthinksO. 

3 Q Anything specific that you fememba about it? 

4 A No. 

5 Q What about Captain Purdie? Have you ever discussed 

6 it with him again? 

7 A No. 

B Q Have you ever discussed it with Oflim Chimy? 

9 A No. 

0 Q Otkrthanthatonecalltbatkmadctoyour 

I trailer and said Betty Currie was upset, did you ever speak 

2 tobim? 

3 A No. ._ 

4 Q Otkr than Officer Tyler, have you spoken to any 

5 otkr wle that you know in Sazct savice about it? 

P4PN July23.1996 

Page 35 

1 A WdLSapntFmkmrc. ’

2 Q ChiuthanSagcaatpprtbemorc. DidyOUCVUtitC 

3 upalyhiugaboUtthis? 

4 A No. 

5 Q DoyouknowwbztLany%ody&ebu.u~ykiadof 

6 ~ordocummtrdhtingwhatbap~tbatday? 

7 A Ibrvcnoi&a. 

8 Q DoycukaowwbukrMmicaLwjntky~~umc 

9 iamtkWhkHouserbatday? 

0 A I da? know lnyseli, no. 

1 Q Didyouhxrthntskbad? 

2 i Y6. 

3 Q wbdidyoubc3rtbI3tfiu3n? 

4 A OfFkw Tykr. 

5 Q DidkteJlyoutbatkuurckbadroeniu? 

6 A I &I? lolow. 

7 BY MR. WISE-ERG: 

8 Q Didyousceallythingirlaayoftk~cutriE, 

9 cauputusamu tbatyouwalookiagulbat&ytbatwwld 

‘0 indicatcc~pukeameinarwasitsbicUyfnxnwhat 

1 ORim Tyk7 lold you? 

2 A StitlyfromwhatOfTiiTykrsaid. 

3 MR_Wf!XNBERG: Irngoingmaskyouifyauwuld ’

4 jusxstepoussideforafew monlaltsandlkll~‘ll~you 

5 LNckin.offKxrBall. 

Pw 36 

1 THE WITNESS: sure. 

2 (WiracsS excused Witness d) 

3 MRWISENBERG: Izttberacordmflecttbattk 

4 witnesgOfficerHall,hasrcrmtuedtbegnmdjuryruom. 

5 MadamFo~dowebaveaquorum? 

6 THE FOREPERSON: Ys, WC do. 

7 MR. WISENBERG: And are that any unautborizd 

8 paxmsprexntintkgrandjuryroom? 

9 m FOREPERSON: -llnz ax m. 

0 0ff1a.r Hall, I’d like to remind you that you are 

I stilllmdcroath. 

2 THE WITNESS: Yes, ma’am. 

3 BY MR. WISENBERG: 

4 Q OffunHall,tkgrandjurorsbavcaskedmetoa!& 

5 yousomequ&onaandI’mawetheymigbthaverapnerbat 

6 lbey’rrgolngtoaakdirrctly. DoyousaydirccdytoMmica 

7 hwinskyorcouldshchavcova-kitdyouaafellowoffrm 

8 saytngsclmuhingtothceffcctoflsktanMlbcr.or”~ 

9 in line”? 

0 A Did I say that? 

1 Q Yes. 

2 A No, sir. 

3 Q Eitbertobercrafellowoff-uxr. 

4 A No,sir. 

5 Q Okay. who was your fellow oflicer 1x1 post that 

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1 day? 

2 A That was Officer Nicdzwiecki. 

3 Q Okay. Didhesaysomcthingliketbattoyouthat 

4 shemighthavc overbeard? 

5 A NotthatIrccall. No. 

6 Q Okay. And did he say something to her, as opposed 

7 toyoyalongthosclincs,"Tskeanumbcr,""Standioliae"? 

8 A No, sir. 

9 Q Okay. In other words, you ‘vc told her that Eleanor 

1 0 Mondale -- at some point, you tell bcr that Eleanor Mondale 

1 1 isinthWhi~HousImdmavbcBaty’sgivinghcratour,is 

I 2 that correct? 

1 3 A Yes, sir. 

1 4 Q And then at & point you tell her the President’s 

1 5 gone to the -- you confirm for bcr the President’s in the 

I 6 Oval offtce, ccrrezt? 

1 7 A Yes, Sir. 

1 8 Q Okay. And the idea would be tbat at some point 

I 9 aroundthatoraftcrthaSeithcroaeofyoutcllshcrorsbc 

2 0 owrhearsyouaUtalkiq,sayingsbcougbttostandinliat 

2 1 or she ought to take a number. Nothing along tbosc lines 

2 2 happened? 

2 3 A No, sir. 

2 4 Q All right. And wzre there any other officers or 

2 5 people in that trailer that you invited her into? 

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Page 38 

Q Okay. What was it - Chincry calls you up and says 

Betty’s mad, that’s not verbatim, but Betty’s upset. Lata 

in the day, Williams tells you at least one point, Sergeant 

Williams tells you that at least ooe point the FVesident 

wanted to fur you, what is it they’re mad about? What is 

that the President and Betty Curie are upset about? 

A That’s spaxlaticm. 1 have no idea. 

Q Okay. No one ever told you, for instance? 1 mean, 

one thing that just springs to mind for me is that you’re 

telling somebody who’s visiting the White House where the 

President is or anything about tbc President. Would that be 

one of the things you spcculati about? 

A I really don’t know. I’m just saying it would be 

speculation on my part to guess. I’m not sure. 

Q Okay. But that’s okay, you can spaxlatc as long 

as we make it claxr that you arc speculating. And oxtainly 

you would have wondered why they were -- would you have 

wondered why Betty Cunie was upset at you? 

A h&~hmm. 

Q That’s a yes? 

A Yes, sir. 

Q Okay. We can’t pick up mm-hmm, we don’t know 

whether it was yes or no. And what is the most logical - 

whatwasthcmostlogicalthingiayourmindatthctim 

PalgP My 23.1998 

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aboutwhyyouttwghttkywemad? 

A Maybcsomui@th.tIhadstatcd.maybcthatIbc 

Raichthadgtmctotkoval. 

Q Okay. It’s this i&a of stating something tn an 

ounidcr. 

A Iprcsumc. 

Q OLay. Butwoainanywaythatdayorhtusaid 

toyouatticlllatcdforyou.tbat’swtlyBcqCurricwas 

upsz that’s wby tk PrcsidPrt was upset. 

A No, sir. 

Q Okay. Is thnt somabiq - I’m sony. ya? 

A JUROR: Offii HalL didn’t you ask? I mc~a 

hctbcy’retingyouyourjobmightkontkIinc_ 

THEWITNESS: WcUIhedaskd.butnobodyimd~y 

answus. 

AJUROR: whatdidyousay? Imam,wbat7HEWITNESS: ljustsaidw&why-youknow, 

why-pnstmmbIyisskttpsi%? OrhtkRcsidmtupsa 

at-wI&Icloa’tewknowiflkyitwasmcspaificaIly. 

AJUROR: Bmtkywuemlki&toyar. 

THEWRN?zss: Exactly. sor-ys,IiuquiKd_ 

Nooncbadanyanswrs. 

A JUROR: Wm’t you - I’d k comxnai. I 

mean-I’dwantto@totkbottomofit. Youdidn’t? 

THEWITNESS: TbzwasnothingthatIcoulddo. 

Page 4. 

1 Isxan.mysupaviwf isUingmcblerwaythhgwas 

2 okay,soIjustkftit~tth. 

3 AJ’UROR: Buthowwouldyoulaiuwwhatyoudidwrmg 

4 ~0 that you wouldn’t da it again? You knmv. I’m just curiws 

5 formyrclf~~if~twasmc.Iwouldreallymnto 

6 knowwbstdidIdownmg7 THE-: WcU.Ibiaitofmdwtbut8 A JUROR: So to this day, you don’t know? Yat’xz 

9 sayiqyoudon’tkamv*tyoudidw7ollg? 

0 T?IE WITNESS: nmvi collect 

I AJUROR: Yo~~ncvcrkadmythiu&myntmots, 

2 about3 THE-: we&I’vcbmdIbcrumus about tbc 

4 rtaadinIioctbinganddifFuattthingslikctbat,btx5 AJUROR: Didyouaytotdltiunttatyouwumt ’

6 invohal in tbq yuu didnt ’ know mything &ntt tkat? 

7 mwl-lMss: WcJI.Imean.Ididn’thrdmtffun 

8 mysquvisor,I’mjustsayiagthothpaqkattk 

9 bousc.wlultk Nmmwar:g0ingmUUlUi.IllMijUSt0 AJUROR: SotknitbccamcckartoyouwhyI mEl%m?a!s: wclLI@msno. Yes. Imean2 AJUROR: CculdMs.hwitukyk~~~by 

3Mytbing? 

4 THEWrrNEx? Exclllcmrsir? 

S AJUROR: CcnddMs.hvinskylwcbrmupactby 

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Pa@ 4: 

1 any&iog? Could sk bavc misintcrprce.d anything you tni&t 

2 bavcsaidofdotkz? 

3 THE WITNESS: Possibly. I don’t know. 

4 AJUROR hdocm’toccurtoyoutbatitdid7 

5 THE WITNESS: No, sir. 

6 AJURORz Wkmyousayyoutrial~findoutand 

7 youmrtaakingcple&3&wnstbatofScrgaurtWllliamsa 

8 frolnyolrrntparircr? 

9 THfzWIrNBSs: Iaskal!lqeantWilliamsandCaprain 

0 Purdiebotbrolrymfindou~yolIknow,wby?lXyclinxtly 

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madatmy&fandtiqdidn’tgivcmcanyrc8sons,soBY h4R. WISBNBERG: 

Q DidtbyrcfusctoorjustA No, I don’t know if tlq know. I’m just sayiog 

tbattkyjustsaid~towortyabauthrbat 

cvqything’r-youkllow.Ihedulcutl~tandingrhat 

nothing would - 

A JUROR: Did you dixctly pose tbz question, 

‘why was supposaily tk Resident and Buty Cunic mad with 

me” to Williams and be said to yuu “I really don’t know’“? 

Imcan.whatwastkfcspoIlsc? 

THE WITNBSS: Well. I dont ’ aactly remark rbc 

exact rlialqnr but I mesa I indirectly like asked. 

“Well. what did I do &at would. you know, inspLt tbosc 

comments?” And they just told mc cvaything wns fine and. 

Page 42 

1 you know, don’t worry about it, basically. . 

2 A JUROR: !h they r&l) never gave you an anmm-. 

3 THE WI-INESS: No, ma’am. 

4 BY MR. WISENBERG: 

5 Q Is that something that you’re not supposed to do? 

6 I’ve asked this in a similar way, but in gaxral, is that 

7 something you all are told not to do, not to discuss with 

S visitoq even if tlq’re familiar, even if tbey are invited 

? or used to work at the White House, that you shouldn’t really 

1 tell them where the President is? 

I A 1 think typically that would be the guideline, not 

2 to be -- I mean, it’s been done. but -- 

1 Q I’hatwaswhatIwasgoingtoaskyounext. Ifit 

I is somebody who is familiar to you all, to the ofR_ is 

I it sometimes done? 

5 A YCS. 

1 Q Well, then, what was different about this that yw 

1 think might have ban the mason for the anger? 

2 A I don’t know. I mean, it’s -- 

1 Q Again, you’d be speculating? 

I A I havenoidca why. 

! Q All right. Didanybodyeversayanythingtoyouto 

I this cfftcf that you shouldn’t be saying things like that & 

I this particular person, Monica Lewinsky? 

i A No. 

I 

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Q Did you ever hear anything after this incident 

aboutMonicaLcwinskythatmadtaliehtpooninyowhcad 

and say, That’s the problem, it’s not really that I revealed 

tosomxmtwho%afmqbntvisitorwhemthcPmsidentwas, 

it’s that it was this vi&to?? 

A Didsomtbodyn~tbat? IjustQ No,didyoucvzrbczanythingaboutMonim 

L+zwbkylatathatmadcyouthinkA we& afiq the incidart, yes. 

Q Afterthe-afterwhichincidcnt? 

A ‘Ihatday. Aftcrsbchadkeftthatday. Imtae, 

later;youknow,IhmrdsometbingsthatkindofAJuROR: What things? 

AJUROR: Whatthingsdidyouhear? 

-f’kIBWITNBSS: lhatabewaspossiblythcintcmtha t 

6 theywetewtitingabout. ‘lhestory-I&&t mmember wher 

7 thestoryactuaUyhroke,but,Imean8 BY MR. WISENBERG: 

9 Q ThtMonicaLcwinskystory? 

0 A Yes. But,Imerm,itwasrightaroundthatsame 

1 timeftamc~youknow,Iwashcaringafewthings+that 

2 shewaspomiblytheintemandthenitbrokethat,youknow~ 

3 shcis-I’mnotgoingb~lateaaymorzbutIjrtd4 Q Okay. Okay. Beforethestorybmke-tbestery 

5 brdre-thisincidmtoccumdanDacembs6,1997;pndthe 

Pagch 

f storybrokcinthtWashiagtonPostonJanuary21st. Am&as 

2 Iundemtandwhatyoujustsaid,sometimerightamundor 

3 bcforethcstoryevenbrcaicin&youheardsomenmmtstInit 

6 skmighthaveb&nthtintan,tkinkmthatwhat? l%c 

5 interatbepcmnwhowasthucatthctic!rthat&y? 

5 Or what intern? 

A Justforthe-somethingsthatwunrumomthat 

mxcgoingMwr4that-you~ow,that--intanwas 

caught with the POTUS. 1 mean, just those type of things. 

AndthenQ POTUS being the President? 

A B.xa&ly. 

Q Andthatwhat? Icutyouoff. Andthatthatmight 

bethepersonwhowasA Yes. Yea. 

Q Okay. Allright. Soatamncpointevcabcfomtha 

Lminskyatorybmke,don’tletmeputwordainyourmatth, 

correctmeifI’mwron&atsometimeevenbefotetha 

L%nsky story broke, you heard rumomthatma&youthink 

thatthewomaninthetlaileTthatdaywasthepersonwho 

might have been caught with the President. 

A Pmsibly. 

Q-Inacompmmisingpoaithxt. Isthataumu? 

A Yes. 

Q OW. Andtheaafterthestorybrnkc,atwhattimc 

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did you maliz that Monies Lewinsky was -jc individual wh 

hadbeenatyourtraihzrthatday? 

A Assoonas~sawtknmcinthcpapc. 

Q Okay. You remcmbged the name? Thats ’ a yes? 

A Ye&Sit. 

Q Okay. DidanybodycometoyouafP;theincident 

happmed-sorry. DidanybodycometoyaJafterth:Monil 

Lewin&y story became public and say in any way, implicitl: 

explicitly, “Keep your mouth shut about this-? 

A No, sir. 

Q Wrm Williams first came down, Sergeant Williams 

came down that day, k’s got to find out wke~ was going on, 

did you fim kind of play dumb and act Iike you didn’t know 

whatbcwastnlLiW:abOutbutthcnkindoftcllhimwhat 

hap@? 

A Wcll,Itoldhim--wcll,b:-asfarasIncall, 

he just asked did I say anything offbandtd about possibly - 

that would, you know, upset anybody and I said, “No, I 

just- “andthenthat’swheaIwcati.ntoexactlywhathad 

happened and what I’d said 

Q Okay. But it wasn’t like you didn’t tell him at 

fii and he had to press you and say, “The Presitknt’s 

really mad about this -- * 

A No, sir. 

Q And then you told him more? 

Page 4( 

1’ A No. 

2 Q Okay. And you had not been thnt vay long? How 

3 1onghadyou~inthtSeeretScrviccwbenthisincidtnt 

4 GccuITed? 

! A Approxunately -- 1 came out of training December of 

6 ‘95. so -- 

3 r Q Soyouhadbeenthereacoupleofyears. 

8 A Two years, I’d say. 

9 Q Okay. And had you ham -- how long hsd you had 

0 that post at ti. White House, the post you had that day? 

1 A ~ifi~~,si~month~,~@~~~~. 

2 Q Is that technically something you’re supposed to 

3 do? You said it was cold and you invited ber in. Is that 

4 something you’re supposed to do? 

5 A It’s done. I mean, it’s not - not a wriacn rule 

6 thatyouha~~lIctsombodyin,but-I~ifit’s 

7 rainingorcoldordependingtmif-maybe,lilrefor 

B example. we let - like if there’s a pregnant lady that just 

9 ~upnottoolangagoanditwashofwc~hcrcomein 

D andsitdownbsauseitwascoolerinthe~. Sol it’s done. 

2 Q Okay. l%e other officer on duty, l think you said 

3 ~~~Ni~~~d~tW~~~~u 

4 all scpamtely of talk to you all while you war together? 

5 A lthinkitwassepamtely,because~don’tremanber 

1 any couvusation rc@t!r. 

2 Q Okay. DidktellyaiwhatbckadtoldScrpant 

3 WiUams? 

4 A Didho? 

5 Q DidNhaim+kikllymwhatklmdtoldSqcunt 

6 Wii? 

7 A Idon’ttu~U. 

8 Q During tk rmtnxm cottva~ation. wkn Sa@attt 

9 Wii mid you that tk Rsidcnt carlk that day had 

0 wumdyuufiraLdidyou--wknyoufirstkardifjust 

I bow did it hit? 

2 A Justlikclsaid. Imcahlwasjustkiadof 

3 rho&cd bsuut I didn’t how tiy that would k - you knaw. 

4 Q Anddidyou-andistbatkwsecvatifyoukmv 

5 youwaao’tsupposulto@ll~ylikcthisvisitorwhar: 

6 POlUSwas.ittiida?strikeyouasamajori&acti& 

7 A No, sir. 

8 Q Whatktkno7 

9 A IdWtthtIhddonchsolutcJyut~ 

!D majorlywmog_ No. 

!I Q Okay. Lotluwords-Ijustwaattomakcssun:I 

2 @Sitright. Hc&lLsyouthisoryouthiak11’oscunat@ 

13 13s”okay.ftokisom&odywhacthaPnScutwas,but 

4 things like that hnvc happaled before” ir that what’s goiag 

.s thr~ugb your mind? 

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A Yes,prettymuch. 

Q Okay. “What’sthebigdeal?” Isthatafair 

Satanent? 

A I would say, yes. 

Q Okay. Didyoulikequayhim? Lii-whatA Well. as 1 stated, I- 1 mean, 1 asked, “Well, why 

were they upset?” Or, “Why was he upset?” But nobody - I 

don’tknowiftheyknow. TobehoncsSIhavenoicka 

Q Did anybody - Iet’s talk about WiUiams, Qlinay, 

CaptainPurdic. DidthcyevertellyoutbatMcmicaLwinsky 

badbeenupstbyofbUlFcpeatcdsomeofrbetbingsyoutold 

her about Eleanor Mondale? 

A No. Nobodyeversaidthat. 

Q Okay. bthissometh@youmi&tlmvebeard 

tbIoUghtheIUlIlOrmillsinathcn,the5? 

A Yes. 

Q Okay. Youhave? 

A Well,likeIsaidaboutthe-Imcau,at?erthnt 

happcncdI~l=Ple tommcnting-=l.&somebodyhad 

stated%andinline”typcsalff. 

Q Alltight. AnddidyoualsohearthatMoniaithattllathadIM&MonicJlmad? 

A Idoa’t-no,Idon’tmcallthat,tobchoocst 

with you. 

Q Okay. AlIti&. AndIjustwantedtomakesureI 

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1 gettkstqucncetigh~askstasyoue8ntecallit. You 

2 fvstmentionedtbatBettym@tkwithEleanorMoodaleto 

3 Monicatbatday. 

4 A In a group. Yes. 

5 Q Inagfoup. Andmaykgivingbcratour. ktbal 

6arreet? 

7 A A tour. Yes. 

8 Q Andatsomepoinfthen,youbearthatPO~Shas 

9 goactothcOvalOffiacandMonicaasksyouifk’sinthc 

0 Oval Off& and you respond affTirma.tively. Is that wrrcct? 

1 A Isai&“Yes,Iklievekis.” 

2 Q Okay. AodbowloogaftcrthatwasittbatMooica 

3 I,Aemkyleftthceaild! 

4 A Imca~,IStatdbCfOrC,maybcfifc,tesxuin~tts, ’

5 but I’m not - 

6 Q Howsureatryouoftbat? 

7 A Im ’ not at all. 

8 Q But no visible -asfarasyoucanrecall,no~ 

9 visible-Itakeitshedidn’tnvcatwbenskbcardthat 

Dtzws. 

I A No. 

2 Q But no - you couldn’t tell from any of her 

3 behavior, outward appeatancc, that sk was upset? 

4 A No,sir. 

5 Q Soifsbewagshewasamtainingit? 

Page SC 

1 A Ye&sir. 

2 MR. WISENBERG: Okay. 

3 A JUROR: I have a question. 

4 MR. WISENBERG: Yes. 

5 A JUROR: After she left the bailer, did she walk 

5 off down Pennsylvania Avenut? Or did she go back to the 

7 phone and call? 

8 THE WITNESS: Sk left. I mean. she didn’t make 

9 any more. calls, she just left and weot - I recall her going 

0 towards 15th Street. I believe. 

J BY MR. WISENBERG: 

2 Q Isitfairtosaythecallshad-I’msorry,did 

3 you have mono? Is it fair to say the calls were earlier? 

4 Were tk calls before you told ba Eleanor Mondale was - sh 

5 was calling to try to get a hold of Betty Ctie? 

6 A Ipresume. 

7 Q Okay. So that’s the best of your recollection? 

a A Yes. 

9 MR. WISENBERG: Okay. 

0 A JUROR: Officer Ha& can you estimate how long 

1 shewastkre? 

2 l-HEWITNE%%: After - 

3 A JUROR: No, this wboie incident. 

4 THE -S: Oh, tk whole - 

5 A JUROR: Thar Monica was them Roughly how 19 

P&l July 23,1998 

Page 51 

1 atime? 

2 THE WTINESS: I just -- it’s a guess. Maybe ten 

3 minutes. I’m uot star 100 perant. 

4 AJUROR: Tkwboletime,fromtbetimcthatshe 

5 cametotk~- 

6 THEWITNESS: That’sagucss_Imean7 A JUROR: -untilsbeuult? 

8 THE WITNESS: It could have ban looger 01 shorra, 

9 I doo’t know. Approximately ten minutes. 

0 A JUROR: Offim Hall, do you take your lunch at a 

1 regulartim? 

2 THE-: Usuallywejusttakeit-wckindof 

3 brcakotivcsattk~sojust- 

. 

4 AJUROR: Doyourecallaboutwhattinxitwason 

5 tkitday? 

6 THE WITNESS: Not exactly, no. 

7 A JUROR: ‘I%aok you. 

8 A JUROR: Did Offtar Niedzwiecki iotaact with 

P Monicaatallorwassksotely@kingtoyou? Wask 

D standingnexttoyou? 

1 THE-: FromwktIreeall,kwas&ting 

2 at-tbere’satableaboutrhiswidthkre. FromwktI 

3 recall,kwastalkingmtkt&phooe,butI’mnot 

4 1oopcnrntsPe. 

5 AJt.JROR: ButkmzvergotupaodspoketoMooica? 

Page 52 

I THE-: NotthatItuxU. 

2 BY hiR. WISENBERG: 

1 Q YoumightbavesaidthiswheoIwasoutoFtkroom 

i earlier. DidMooicasaythatanybodywhenskfirstcamein 

5 wascxpectingber? 

i A Idon’tthinkskevermadethatstatement. I 

7 tbinksksaidsbejust-whensheftrstcameup,sbebad 

8 tkgiftsForMsCu&. 

9 Q Okay. Aod you did not find kr on WAVES, is that 

0 conect? 

1 A Ihalsmrst. ’

2 Q SoskwastryingtocallMs.Currietogetwtbe 

3 WAVES list? 

4 A Idon’tknow. 

5 Q Youdoo’tknow? Skjustsaid,1naultogeta 

6 boldofMs.CMic.” 

7 A Yes. 

B Q Didskseemdspaatcwbenskwasttyingtogeta 

9 bold of Ms. aaric? 

D A No, sir. 

1 MR. WISENBERG: Okay. 

2 A JUROR: Could Ms. Jxwinsky have oxrkard 

3 anytbingthatwasbeingsaidontkpbrmebyOFfim 

o Nialzwiecki? 

5 THE WTI-NESS: I don’t know. 

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I A JUROR: Was sk cl- to him than you? 

2 THEWTlNESS: Idon’traallifIwucclwcrork 

3 was closu. I’m not sure. to k booest with you. 

4 AJUROR: Thsnkyou 

5 AJUROR: DidtktwoofpuboldnEanvczsationin 

6 haprcsaxed~thismiire~skwasdsxe? 

7 THE WlTNESS: Not that I raall. I pm much 

8 spok with Ms. Lcwinsky. I don’t raambcr talking to Officer 

9 NiakwiccLi. 

I .O BY MR. WISENBERG: 

1 1 Q You mahonai that you knew who Eleanor Mwdak 

1 2 was. How often had you scn Ekacor Mondak kforz? 

I .3 A lsawhaoneothatimcandthatwasbacktbc 

1 .4 previous summa. 

I 5 Q Okay. Sk bad visited tk white House? 

1 16 A Yes. 

I 7 Q Andyoubadbcmattkpostagain? 

I ,a A Ys. tk old aortb=t gate 

1 .9 Q Okay. And you had - tk same gate? 

2 !O A Well. ycz. It’s tk same gate ~hnicfdly 

i !1 speaking. 

i !2 Q Andyoubadlethain? 

1 !3 A IkkveIwastkOtXtbstissucdthepasstbat 

2 !4 day. Yes. 

1 !5 Q Okay. AndrkwastbczetoractkPzsidmt? 

Page 54 

1 A IthinkshcwastkretcsuMs.Cunie. 

2 Q Okay. Do you know wkther or not she saw the 

3 President that day? 

4 A I have no idea. 

5 Q And you had seen - I unckrstand you said when I 

6 was out of the room you had sari Monica before, one time 

7 before? 

8 A ~atsamesummer. Ipresume itwasher. 

9 Q Was there anything in particular about that 

1 0 incident that you recall, the previous one? 

1 1 A Wl-KTI,hsUmmer? 

1 2 Q Where you had sari her before in the summer. 

1 3 A No. 

1 4 Q Did you see her with the Resident? 

1 5 A No, sir. 

1 6 Q Doyouruxillwhoyousawherwith? 

1 7 A Ms. Currie. 

1 8 Q All right, It had ken an occasion when you let 

1 

1 

2 

1 

1 

1 

2 

9 her m? 

!O A No. 

!I Q Okay. All right. You hadn’t heardanythingabout 

12 her at this time, at the time of the northwest gate incident. 

!3 A No, sir. 

!4 Q You said you talked - you mentioned those were tk 

I5 only people you talked to the same day at work. 0th~~ than 

i-l July 23.1998 4 

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your wife did you talk to anybody abour it? 

A No.&. 

MR WISENBERG: Okay. That’s all I’ve got. 

Didjmlbavesomequ5lions? 

Ms.WlRTH: No. 

BY MR. WISENBERG: 

Q Letmcaskyouoncquestron. Iwasoutoftkmom 

wbmyw&fxd&outkrcomingbyintbesummcr. War 

pJeWWSEWbZlSkcamCbyhtbcSUUtWZ ofkrkving 

b&nwavcdinona~spasscrwavadinasapraspcrsan? 

A 

Q 

A 

Q 

Ibat? 

A 

Q 

Not o my knowkdgc. No. sir. 

Okay. DidyouNzrkarrnmmrtotkteffat? 

No. sir. 

Sug!amtWilliamslbevutoldyouanydlillgrbout 

No. sir. 

okay. DoyouthinkIk~sugeaIltWiUiamswas 

lryiagtopnJs!xtyoutktdayandCapeinRPdic? 

A Idon’tknow. 

Q Rorectyoufmmpossibly&f& 

A Ihavcmibwhattkywurtryingtodo. 

Q Okey. Doyoutbinktbtmi&bcmunasoa 

~tWiUiamsmcr&malittoyoula~? Hadmentiooad 

?o you lk Resident’s stanaent dout wanting Rl fllc yea? 

A Ihs~noi&awbykbmugbtitup. 

Page 5c 

1 MR. WISENBERG: Any fmtbcr questions? 

2 (No =Vn=.) 

3 MR. WISENBERG: May the witness be excused? 

4 THE FOREPERSON: Yes, he may. 

5 MR. WISENBERG: T&I& you vay much. You’re 

6 excused. 

7 THE WITNESS: Thank you. 

a THE FOREPERSON: Thank you 

9 (ThZwitnesswaSCXCUZd.) 

D (wtmpo&at2:53pm.thetakingofoestimany 

1 inthepresmce ofafullquorumoftkGraudJurymrs 

2 concluded.) 

3 *a*** 

Page 53 - Page 56 

Divcrsificd Rmorting Services. Inc. (202) 296-2929 
1281 

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

- 1 - 

OFFICE OF THE INDEPENDEhT COUNSEL 

Dafs of nanscription l/27/98 

RICHARD E. HALPERIN, Executive Vice President and Special Counsel to the 

Chairman, MACANDREWS & FORBES HOLDINGS, Inc. (MFH) was made available for 

interview by his attorney, CHARLES STILLMAN, at the law firm STILLMAN and 

FRIEDMAN, 425 Park Avenue. STILLMAN and his associate JOHN B. HARRIS were present 

during the interview. All persons present tiere advised of the pu ose of the interview and the 

official and personal identity of Investigators 0 and rp. HALPERIN thereafter 

provided the following information. 

HALPERIN first became aware of MONICA LEWINSKY on or about 

December 11, 1997 when he received a phone call from VERNON JORDAN, an attorney with 

the law firm AKIN, GUMP in Washington D.C. and a member of the Board of Directors for 

REVLON, Inc. HALPERIN recalls that he either had LEWINSKY’s resume at the time of this 

call or he received it that same day. In this phone call Jordan stated that MONICA LEWINSKY 

was a young, enthusiastic hard worker who was relocating to New York and wanted to obtain 

work in the private sector. JORDAN asked that HALPERIN meet with LEWINSKY and assess 

her for a New York based opportunity. JORDAN indicated that LEWINSKY is interested in 

Public Relations work and she should be considered at the “entry level”. JORDAN did not 

characterize LEWINSKY as being associated with the White House or any particular member of 

the Administration. HALPERIN does not recall JORDAN giving any indication of how he knew 

LEWINSKY or what kind of relationship existed between them. 

HALPERIN said it was not unusual for VERNON JORDAN to call him and 

likewise it is not unusual for JORDAN to call him with an employment recommendation. 

HALPERIN recalls possibly 3 or 4 other times that JORDAN has recommended someone to 

MFH or REVLON. HALPERIN recalled that JORDAN recommended DAVID DINKINS, 

former mayor of New York City, as a board member and on another occasion he recommended a 

secretary who was employed with AKIN, GUMP but was wanting employment in Europe. She 

was placed in the REVLON European operations located in Paris. HALPERIN could not recall 

any other specific recommendations from JORDAN. . 

HALPERIN recalls that on December 15, 1997 MONICA LEWINSKY called for 

him and because he was not available, his secretary took a message that she had called. 

HALPERIN stated that he then faxed LEWINSKY’s letter and resume to JAYMIE DURNAN, 

Senior Vice President and Special Counsel to the Chairman and to JIM CONROY, Senior Vice 

President of Public Affairs, both with MFH. 

Invewgation on l/26/98 at New York City, NY File X 29D-LR-35063 

by _ a mtcdktrrcd l/27/98 
1282 

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

29D-LR-35063 

Continuation of OK-302 of Richard E. Halperin- ,On l/26/98 . Page 2 

LEWTNSKY called HALPERIN between the 15th ‘and 17th of December and 

informed him that she would be in New York of December 18, 1997and would like to be 

interviewed on that day. LEWINSKY came to the headquarters of MPH at 35 East 62nd Steeet 

alone and at the appointed time where HALPERIN and JIM CONROY conducted the interview 

in HALPERIN’s office. 

HALPERIN recalls that LEWINSKY was determined to be a typical young, 

capable, enthusiastic Washington, D. C. type individual who described the kind of opportunity 

she was looking for. HALPERIN inquired about other intetiews set up for LEWINSKY and 

she indicated that she would be interviewed by AMERICAN EXPRESS and BURSONMARSTELLER a large Public Relations firm. HALPERIN advised that he spent some time 

talking to LEWINSKY about her career path and explained to her about the differences between 

the client side of the business and the agency side of the business. LEWINSKY indicated a 

preference for the client side and specifically liked the idea of working at REVLON. 

LEWINSKY said she would be living with her mother who lives in Manhattan. HALPERIN 

stated that even though he does not usually counsel with potential employees, it was not clear in 

her letter that she desired to work for REVLON. 

HALPERIN stated that this was “clearly an accommodation for VERNON 

JORDAN”. HALPERIN had earlier that week sent LEWiNSKY’s resume to DURNAN for his 

consideration. HALPERIN recalls that on the following day, LEWINSKY called his office and 

left a message thanking him for the meeting on the previous day. 

HALPERIN went on vacation and upon returning learned that LEWINSKY sent 

him a letter dated December 23, 1997 again thanking him for the interview. 

HALPERIN recalls that on January 21, 1998 he was astonished to hear on the 

news early that morning that there was an allegation concerning President BILL CLINTON, 

VERNON JORDAN and MONICA LEWINSKY. HALPERIN was also aware at the same time 

that HOWARD GITTIS, Vice Chairman and Chief Administrative Officer, MPH, was intending 

to meet with VERNON JORDAN for breakfast on this same morning. HALPERJN called for 

GITTIS at about 7:30 am knowing he was probably walking at that time and left a message. 

GITTIS called him back at 7:45am (before he met with JORDAN) and HALPERIN told him 

about what he had heard on the morning news. HALPERIN also told him that he had 

interviewed Monica LEWINSKY during December of 1997 and that she may have already been 

hired. 
1283 

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

29D-LR-35063 

Continuation of OK-302 of Richard E. Halperiri .OII l/26/98 ,page 3 

HALPERIN is described as follows from observation and interview: 

Name: 

Race: s 

Sex: __ 

DOB: _ 

SSAN: L 

Residence: _ 

I - 

Title: 
1284 
1285 

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

- 1 - 

OFFICE OF THE INDEPENDENT COUNSEL 

Date of rrarrscnpdon 4/2/98 

RICHARD HALPERIN, Executive Vice President and Special 

Counsel to the President, MC ANDREWS & FORBES HOLDINGS(MFH), 

35 E. 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. 

MFH is a holding company which provides the legal and 

financial overlay to the operating businesses which it controls. 

Some of the companies owned by MFH are: 

THE REVLON GROUP, cosmetics and related products 

COLEMAN CORPORATION, camping and recreation products 

CAL FED, a thrift institution 

CONSOLIDATED CIGAR, tobacco products 

PANAVISION, cameras and film industry equipment 

(acquisition pending) 

MAFCO, flavors and flavorings 

HALPERIN talks to VERNON JORDAN approximately every 

other month, usually in regard to: (1) charitable contributions 

to the MC ANDREWS & FORBES FOUNDATION and the REVLON FOUNDATION; 

(2) legal matters concerning MFH or REVLON. JORDAN's law firm, 

AKIN, GUMP, STRAUSS, HAUER & FELD is on retainer to the 

companies. JORDAN does legal work on a continuing basis for 

them. 

HALPERIN's contact with JORDAN is generally over the 

telephone. He uses telephone number i-which is 

located in his office. In the past he has telephoned JORDAN at 

his office in Washington, D.C. He has no recollection of calling 

JORDAN at the AKIN GUMP office in New York. In addition, he has 

not contacted JORDAN at his residence in the past calendar year. 

In the past several months, HALPERIN has received two calls from 

JORDAN. One of these calls was regarding MONICA LEWINSKY. The 

other was on an unrelated issue. 

__ 

Investigation on 3/27/98 at New York, New York File% 29D-OIC-LR-35063" 

by - Date dictated 4/2/98 
1286 

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

29D-OIC-LR-35053 

Continuationof OK-302 of RICHARD HALPERIN .On 3/27/98 . hpe 2 

On December 11, 1997, HALPERIN received a telephone 

call from VERNON JORDAN. The purpose of the call was to discuss 

MONICA LEWINSKY and her securing employment in New York. JORDAN 

said that she was a bright, energetic, enthusiastic, young 

candidate seeking an entry level position in public relations. 

JORDAN requested him to interview LEWINSKY and give her career 

advice, as well as explore possible employment opportunities with 

MFH or their corporate holdings. He took JORDAN's statements as 

a recommendation for employment. There was no implied time 

constraint or requirement for fast action. HALPERIN did not 

think there was anything unusual about JORDAN's request. 

LEWINSKY was going to call HALPERIN's office to set up 

an appointment. She did, in fact, telephone to set up an 

interview date and subsequently called the office several times 

to leave messages. 

An interview with HALPERIN and JAMES CONROY, Senior 

Vice President for Corporate Affairs, was arranged for 

December 18, 1997. HALPERIN said his conducting entry level 

interviews was not unusual for potential employees of MFH. He 

described the firm as thinly managed, which requires senior 

executives to do such interviews. HALPERIN mentioned that MFH 

has approximately 180 employees in offices located around the 

United States, approximately 30 of these are senior executives. 

At the time, HALPERIN was looking for a secretary, 

which he believed was a position in which LEWINSKY might have 

interest. He sent her resume to CONROY, as well as to JAYMIE 

DURNAN, Senior Vice President, MFH, who also has some Human 

Resources (HR) duties at the firm. HALPERIN was scheduling the 

interview to see if she would fit into their operation. He has 

no specific recollection of the actual interview, but he did 

determine that she was not interested in a secretarial position. 

When LEWINSKY contacted MFH, she said she was calling 

at VERNON JORDAN's suggestion and wanted to set up a time for an 

interview when she would be in New York. 

to be a secretary, 

Since she did not want 

and there was no public relations work at MFH, 

CONROY and HALPERIN considered from the outset the possibility of 
OIC-302a (Rev. 8-19-94) 

1287 

29D-OIC-LR-35063 

Continuation of OIC-302 of RICHARD HALPERIN ,On I/27/98 .page 3 

element of crisis management. In interview, LEWINSKY said she 

understood the limitations of opportunities, given her 

experience, and was flexible as to what might be offered and 

accepted. As to the question of her suitability for a 

secretarial position, HALPERIN said all their secretaries are 

college graduates and highly qualified for the positions. An 

offer of secretarial employment would not be unusual for a person 

of LEWINSKY's background. 

HALPERIN found LEWINSKY to be enthusiastic, bright, 

energetic, but lacking experience. She seemed to be a quick 

study. 

As a matter of practice at MFH, it is not unusual to 

have a highly qualified applicant referred to them and then 

finding a position within the organization for that person to 

fill. The less likely scenario is having a specific vacancy and 

locating a person to place in it. 

It was HALPERIN's understanding that after her 

interview, LEWINSKY would be "shipped to REVLON." 

Shortly after the day of the interview, HALPERIN went 

on vacation and did not return to work until the first Monday 

after January 1, 1998. He had no further contact with JORDAN 

about LEWINSKY. While he was on vacation a note arrived from . 

LEWINSKY thanking him for meeting with her. He did not discuss 

LEWINSKY with the owner of MFH, RONALD PERELMAN, or mention the 

matter to anyone else. 

JAYMIE DURNAN met with LEWINSKY on January 8, 1998. 

After the interview, on the same day, DURNAN advised HALPERIN 

about the event. He told HALPERIN that he was going to send 

LEWINSKY's resume to REVLON. During the interview, DURNAN 

learned that LEWINSKY wanted to work in public relations, and 

that she wanted to be on the client side of the business. 

HALPERIN would expect that DURNAN would be a logical person to 

meet with LEWINSKY, an entry level person, given his human 

resources role at the company. In addition, DURNAN had worked at 

the Pentagon, as did LEWINSKY, and could relate to the working 

experience there. HALPERIN could not remember DURNAN's 

impression of LEWINSKY; however, he would not have forwarded her 
1288 

OIC-302a (R:: 8-19-94) 

29D-OIC-LR-35063 

Continuanon of OIC-302 of RICHARD HALPERIN .On 3/27/98 ,page 4 

resume to REVLON if he thought she was not a competitive 

candidate. There was no understanding as to whom LEWINSKY would 

be referred at REVLON. 

HALPERIN assumed that DURNAN knew about the referral 

from JORDAN. The cover letter written by LEWINSKY, naming 

JORDAN, was attached to the resume and he assumed DURNAN read it. 

After DURNAN's January 8, 1998 interview with LEWINSKY, 

HALPERIN had two conversations with him (on that day). In the 

first, he advised HALPERIN that it had occurred. At the time of 

the second conversation, he advised HALPERIN that he received a 

telephone call from RONALD PERELMAN, who said VERNON JORDAN had 

called to ask if "we could be helpful" to LEWINSKY. The 

implication was that this call to PERELMAN had been recent. 

HALPERIN and DURNAN have frequent contact during each business 

day. DURNAN works for HALPERIN which occasions their 

interaction. 

HALPERIN did not find PERELMAN's involvement to be 

unusual. When asked how this situation struck him, HALPERIN 

stated that it did not strike him any way. He assumed that 

JORDAN was really trying to help LEWINSKY. 

At the time she was hired, HALPERIN had not been 

informed that LEWINSKY had been offered employment by REVLON. 

When the news became public as to the allegations about 

MONICA LEWINSKY and President CLINTON, HALPERIN recognized her 

name on the reports. There was also a reference to JORDAN on the 

news which further made the connection between LEWINSKY and MFH. 

HALPERIN said he is usually in the office by 7:00 or 

7:3O a.m. eadh day. On the day the allegations were publicized, 

HALPERIN was at his office. Upon learning of the news, he first 

called BARRY SCHWARTZ, General Counsel for MFH. He told SCHWARTZ 

that he had interviewed LEWINSKY and detailed the story that was 

being reported. Until that time SCHWARTZ did not have any 

knowledge of LEWINSKY. ._ 
1289 

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

29D-OIC-LR-35363 

Continuauon of OK-302 of RICHARD HALPERIN ,On 3/27/98 *page S 

The second call he made was to JAYMIE DURNAN, at which 

time he learned from DURNAN that LEWINSKY had been offered 

employment by REVLON. 

He then called HOWARD GITTIS, General Counsel, MFH, 

because he was aware GITTIS had an appointment with JORDAN in New 

York that very day to meet for breakfast. He told GITTIS there 

was a story on television that VERNON JORDAN had helped MONICA 

LEWINSKY, a former White House intern linked to President 

CLINTON, get a job with REVLON. GITTIS said he had heard the 

news, but was not aware there was a connection between LEWINSKY 

and MFH. 

HALPERIN did not attend the breakfast with GITTIS and 

JORDAN, nor did he attend the usual MFH executive breakfast that 

morning. 

The last conversation HALPERIN has had with JORDAN 

on December 11, 1997. He has.not received any written 

correspondence from JORDAN. 

was 

On the morning the news reported the LEWINSKY-REVLON 

connection, a meeting was called at MFH with upper level 

executives along with the corporate counsel, CHARLES STILLMAN. 

It was decided that REVLON would suspend the hiring process for 

LEWINSKY. A reference to WILLIAM GINSBURG, attorney for 

LEWINSKY, was seen in the press. They located his law office the 

same day and faxed a letter advising him that LEWINSKY's offer of 

employment was being suspended. There was no response from 

GINSBURG's office. 

LEWINSKY's employment offer was subject to checking her 

references. Telephone calls were made to her reference at the 

Pentagon. When doing lower level hiring, MFH and their holdings 

always check references and do some background investigation. 

Letters of acceptance sent to newly hired employees are 

conditional on acceptable reference checks. 

, 

HALPERIN was aware of the situation with WEBSTER 

HUBBELL and his legal problems which occurred after he was 

retained for his services. When asked his opinion of this 

matter, HALPERIN said it had been an unpleasant experience for 
1290 

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

29D-OIC-LR-35063 

Continuation of OIC-302 of RICHARD HALPERIN . On 3/27/‘98 .Page 6 

the company; however, this matter did not come to mind in regard 

to LEWINSKY and the JORDAN referral. According to HALPERIN, MFH 

was not "gun shy" about dealing with LEWINSKY, in view of the 

fact that JORDAN also referred HUBBELL for employment. 

HALPERIN has not been contacted by anyone at the White 

House or ROBERT BENNETT. There is no defense agreement with the 

White House. 
1291 

Richard Halperin, 4/23/98 

OIC Deposition 

Page 1 to Page 39 

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 
1292 

Richard Halperin, 4123198 xlMx(l/l ) 

Page 1 

::: 

I-. 

,-a 

:;I ----_---------------x 

:4:1X RE: GRAND JURY INVESTIGA1:ON 

.c,--------------------~ ,-. 

161 

17: 

!B! DEPOSITION DEPOSITION of RICHAR!Z RICHAR!Z f. HALPERIN, HALPERIN, held at 

[9]the offxes of Messrs. Messrs. Stiliman, Stiliman, Frxdman Frxdman L Shaw, 

!:0]425 !:0]425 Park Avenue, Avenue, New York, Heu York 10022, on 

!:l]Thursday, !:l]Thursday, Aprli 23, 1998,. caaencing caaencing at 9:15 

::2]o'clock ::2]o'clock a.m.. before Annette Annette Forbes, Forbes, a Certified Certified 

;:3]Shorthand ;:3]Shorthand (Stenotype) (Stenotype) Reporter Reporter and Notary PublLc 

:14lulc.'.;n and for the State of Seu York. 

iI51 

i161 

il71 

I181 

iI91 

1201 

:211 

I221 

:231 

:241 

[25] 

Page 4 

1;; 

: 2 1 reporter thus morning. and a transcnpt will be 

: 3 I made that will ultimately be presented to the 

! 4 I rand ju whrch is investigating these matters in 

;;;%Iashing%n. D.C. 

Do you understand that? 

17: A Yes. 

I81 Q Everything as t said. that you say 

! g]wilI be taken down, and t at s Important for a 

[ :o 1 couple of reasons. 

First, you have a Fii Amendment 

iii; right not to say anything 

i : 3 1 incriminate you. 

that may tend to 

!i4: Second. since eve hrng IS taken 

I :5]down, we will have an accura T e record of what has 

rlslbsen said todav. 

And you should just be aware that it 

i :i i is against Federal law to knowingly make a 

[ I 9 1 misstatement of material fact dunng the course of 

:201tb deposition. That can be perjury or other 

rtl~cnmas. and those felonies are punrshabie by law. 

1221 Do you understand that? 

[231 A Yes. 

[241 Q In a normal deposition you might be 

t 2 5 j provided a transcript. but because we are 

Page 2 

!;;APPEARANC s: 

i3i OFFICE d F THE INDEPENDENT COUNSEL 

1001 Penns lvania Avenue, N.W. 

!41 Suite 4QOyNorth 

i51 

Washington. D.C. 20004 

BY: THOMAS H. BIENERT. JR., ESQ. 

:61 Associate lnde “dent Counsel 

STEPHEN BINHA/? ESQ. 

Associate Independent Counsel 

[l? 

Page 5 

:71 

!3! 

:51 . 0: ::. 

*I ::q, 

a*... 

:131 

:14j 

'151 

:161 

-._. 

zaj 

~‘9; :;, .-i! .-. , 

.--, ._^> 

I--! 

::3j 

::4; 

;r51 

12 ~conducting this deposition in lieu of grand jury 

I 3 1 teshmony. we will not be providing a transcript 

r 4 I of thus momin 

t 51 providing that s 

s ‘ deposition and we will be 

ranscript to the grand jury and 

[ 6 lmll be reading it for them. 

171 Normally if you were to testii 

t 8 ~before a grand jury, there are rules of secrecy 

[glforthe grand ju 

r 

. 

r101 What hose mean is that the court 

I i 1 I reporter. Mr. Bieneti and I are bound bv those 

Page 3 Page 6 

1. / 

_-, 

~zIRICHARD E. HALPERIN.calledas 

i3i a witness, having been first duly sworn by 

:4j Annette Forbes, a Notary Public of the 

:5: State of New York, was examined and 

61 ‘ testified as follows: 

i 7 ; EXAh0NATION 

.I ‘ BY MR. BINHAK: 

y: Cl Good momin 

7 ‘ 01 Why dont ’ you 

f i I i spell it for the record. 

sta 8, 

Mr. Halperin. 

e your name and 

A Richard E. Halperin. 

[:I 

i z I part of that trial 

:31- Do you understand that? 

I41 A -Yes. 

Q Also, there is a reporting function 

I z lof the Oftice of Independent Counsel and as part 

r 7 J of that reportins function. the office will 

r 8 I prepare or may prepare a report, final report of 

[ 9 J all the work that the office did, a more specific 

I 1 o 1 report of this. Excerpts of your transcript may 

t 11 J appear in that report. 

1121 Do you understand that? 

[I31 A -Yes. 

[I41 Q Finally, Mr. Bienert and I work with 

[ 15 ] several investigators and agents. You m’ 

I i 6 I met one of them last time we were here. 

ht have 

p ‘ hose 

[221 A Yes. 

I231 Q You understand the Fifth Amendment 

[ 2 4 I right that I~P$I~~~I to you before, nght? 

[25i 

Page 1 to Page 6 
.- 1293 

asA Richard Ha&win, 4/23!98 XMAXW’Z) 

Page 7 

!11 

[:I Q We are atso here at your attorneys ’

[3 ~offrce and you are represented by an attorney, 

r4iCOTTeC1? 

i5i A Yes. 

Q Can you state for the record who 

l;ithat attorney is? 

A 

~~~S-t-G+-m-a-n. 

Charles A Stillman, 

i17i 

1181 

A -Yes 

Q ThelastthingIwillsayisifI 

uestron that you dont ’ understand and 

0 darify. phase ask me to, I will 

(11 

Page 8 

121 Q You understand everything I said, 

[ 3 land you are willing to proceed this morning under 

r 4 lthe rules that I have iust set out? 

i5i A Yes. - 

[Cl Q Why dont ’ you just explain, please. 

17 1 the position you have and where you work and how 

r 8 llono vou have been workino there and the duties 

i 9 i yocriave rde#;gg;;t$ is executive vice 

i :t 1 resrdent and speaal counsel to the chairman at 

[ 12 1 & acAndrews 8 Forbes Holdings. Incorporated. We 

[ 13 1 are a diversified hotding company based in 

~14 IManhattan. And I have been employed here since 

[ls;February of 1994. 

1161 Q What are your duties as executive 

[ 17 I vice president and special counsel, just 

; I 3 1 generally? 

[19i A Generally, I handle government 

[~olrelabons. I handle real estate and special 

121 lprotects and special assignments as they arise. 

;:2: Cl Why dont ’ you ust ‘ give a sort of 

[ 2 3 1 brief thumbnail sketch of Ma CA ndrews 8 Forbes, 

I141 You said its ’ a holding company? 

[25]Just tell us - 

Page 9 

Ill 

A We are a diversified holding 

Iiicomoany. Our largest company is a company called 

(4 j Revion. a consumer products company based here in 

rs]New York. 

if i thrift In California. CALFED. formerly 

We have an interest in a ia? 

rrst 

[ 8 1 Nattonwide. 

r:ziC’ 

We have an interest in Consolidated 

P 

called MacAndrews 

[III& 

\ ::; in a company call Panavision in the entertainment 

[ I 4 1 business. 

We have an interest in Meridian 

~:~~Sports. which is a Master Craft Boat Compan 

1171 0 Do you have an interest in Co z man? 

A We lust divested. We had a 

[ :ii controlling interest tn the Coleman Company, which 

r:olis based n Wichita. Kansas. 

We sold our interest in the Sunbeam 

IziiCompany and it recently closed on that 

[ 2 3 1 transaction. 

Q 

~~~~Forbes have? 

How many employees does MacAndrews B 

Page IO 

Ii. 

[2: A About 170. 

!?I Q Of those 170. about how many of 

[ 4 1 these are senior people. executives7 

15: A Maybe 30. 

16: Q As part of your job at MacAndrews 8 

;7 1 Forbes, do you have occasion to deal with outside 

rs~counsel? 

[91 A Yes. 

110: 0 

I 1: I Jordan? 

Do you know a gentleman named Vernon 

r12: A Yes. 

Q Does he have a relationship with 

i :: j MacAndrer ayFobes in a professronal capacity? 

1151 

111 

Q 

Page 11 

i:&ith Mr. Jordan? 

Do you have a personal relationship 

[4! A I know him well. 

Q 

t z ; Do YOU see him sociallv at all? 

Do you have a social relationship? 

[71 A No. - 

[8! Q In a typical one-month period, about 

r 9 1 how manv times on averaoe. and I am iust askino 

[ ioi just an ap’ 

[ 111 usually ta ii 

roximate. aboul how many ti~sGfo~j;ou ‘

to Vernon Jordan? 

[El A Probably eve other month. 

[13i 0 1 

rl41that might come up in a conversation 

And what ma ers are p~;~y~F~rs 

te’ 

[ 15 I and Vernon Jordan? 

[16: A I my not have mentioned, sir, in my 

I 17 I explanation of my uties that I am also the 

[ 1s ! resident of numerous foundations, MacAndrews 8 

[ 191 I-! orbes. Revlon Foundation. 

[ZOj So I will speak to Vernon about 

[21 lcharitable contributions. I will talk to him 

[zi labout community relations and I will talk to him 

(23 I about ovemment relations and sometimes I will 

[241talk to 8. im about tegal matters. 

[25; Q Since November of 1997, can you put 

Page 12 

[ -7 Ia number on how many times you have spoken to 

I 3 1 Vernon Jordan? 

141 A I could estimate two or three. 

[5: Q Of those times that 

I 6! him, did you see him in person or dy 

ou spoke to 

[ 7 J him on the tele hone? 

Id you talk to 

13; A 

l9! Q 

6r-r the telephone. 

Of those meetings, did you ever have 

lojany discussions with him about an individual named 

111 Monica Lewinsky? 

I121 A Yes. 

1131 Q Why dont ’ you tell us what the 

I 14 ;discussions,, as best 

I 15 I Monica Lewrnsky in 

ou can remember, were about 

t K at tekphone call. 

116: A s-he . --I 

-Q 

--.-. 

il i that would 

And if you can put a date on it. 

i191 

be meat. 

A “On or about December llth, I 

[za!received a letter from Monica Lewinsky that 

~2 I! referred to Vernon Jordan and Vernon had called 

rz! me to tell me that I would be getting a letter and 

[z 3! resume from Monica Lewinsky, who was a White House 

[ 2 4 I intern formerly and currently at the Defense 

j 2 5 I Department who was relocating to New York and 

Page 7 to Page 12 OlCStan 
.- 1294 

asA Richard Halperin, 4/23198 

Page 13 

[I! 

(2! looking for opportunities in the public relabons 

13 Iworld at the entry level. 

I cant ’ recall 

Izi had Ms. Lewinskys ’ le tf 

recisely whether I 

er at hand when Vernon 

[6]called. I may have. 

Q But if 

1; i letter receiving the p 

ou did, receiving the 

[ 9 J at the same time? 

K one call occurred roughly 

r101 A Roughly the same time. 

[ill Q Wnhn a few days of each othen 

c12: A Yes. 

[131 Q Lets put aside the letter for a 

[ 14 1 second now 

When you spoke to Vernon Jordan and 

i :z i he had told you about Ms. Lewinsky and the fact 

[17tthat she wanted to relocate to N+w York, did he 

[ 1 e 1 ask you to act on her in any partlwbr way? 

A Well, he Saki she was a bright young 

i:ziwornan who was energetic and enthusiasbc and 

t2 11 wanted me to basicall 

(22 lrelocating to New Yo x 

give her advice on 

and the vanous 

r23lopportunrtii in New York, encouraged me to meet 

i24 j&h her. 

I251 Q Was there anything unusual about 

Page 16 

Ill 

0 Wh 

iSlat that meeting an J 

dont ’ you describe what happenec 

14’ A 

when rt hap pened. of course. 

ii j recoltection. 

Perhaos vou cou d refresh mv . I 

[Cl MR. BIENERT. Could it have 

[71 been around December Bth? 

[El THE WITNESS: Yes. 

[91 Q Does that sound about right? 

[lOI A Yes. 

1111 Q 

112lmeeting? 

December 8th. did you have a 

1131 A Yes. I met with her and asked Jim 

ii4 i Conroy. our senior vice president of public 

ilsjaifairs; to join us. 

[I61 _ Q First of all, where was that 

[17lmeeting? 

[I81 A 

0 

In my office in New York City. 

1191 

1201 A 

What is the address of your offoe? 

35 East 62nd Street. 

iZ;in the morning or 

Q W..y$$e;fthe;~tiw was 

A I believe it was in the morning, but 

I::!perhaps I shoutd check that. 

(251 Q I dont ’ think tt% very important. 

Page 14 

- [ :: 1 that the request that Vernon Jordan was asking 

13 1 

r 4 1 b 

oui in light of your general experience as a 

usrness executive, In general, and,your business 

[ 5 1 dealings wih V;$on Jordan In pamculafl 

161 

0 Did he ask you to work on any 

iii particular kind of timetable with Ms. Lewinsky? 

191. A No. 

Q At the time you got this call from 

[:?;Mr. Jordan were you looking for anybody in 

r 12 1 particular or were you looking to fill an 

r 13lparticular rrhoro;, at MacAndrews 8 F orbes? 

I141 

(15: Q 

rl6;which ones. 

Why dont ’ you describe which one or 

A M secretary of seven years had 

I :~;recently resigne d and I was looking to re lace 

[ ;;; ;;r, and that was the specrfic job I was tl!inking 

[LL 

Q 

ifiithat openina? 

Would Vernon Jordan have known about 

.~~_ 

123: A- No. 

Q Were there an other specific 

15: i openings that you knew abo llr at that time? 

Page 15 Page 18 

[I! 

r2: 

13; 

$ $tey,acAndrews? 

I;: 

A No. 

Q Is it unusual for MacAndrews 8 

16: Forbes, people, executives there to intervrew 

17 1 peo le even though there is not a s 

[ 9 1 at hf acAndrews ,& Forbes th$t may K$%aW? 

r ythe pe=o”Aymop~ns??gfy. someone hat 

I :? i ability we will meet them with an eye to either 

[ 12: referring them somewhere. its ’ not unusual for us 

[13lto meet a 

r 

rson who comes highly recommended. 

And Im ’ not meaning to suggest that 

i : t ; Ms. Lewinsky would necessarily have been 

[ 16 j app~Op&te or inapprOpriate for the SeCIt%~S 

[l~jposrtion. Im ’ just asking the general quesbon, 

[13lyou unde%tanotit;t, ’ nght? 

[19i 

0 

~~~~1 just said? 

Your answer is the same, given what 

[r:: A Yes. 

I231 0 

[ 2 4 ! Ms. Lewinsky? 

Did you get a chance to meet with 

(25; A Yes, I did. 

ii, 

I: i match 

So I thought he might be able to 

Ms. Lewinskys ’ abilitiis with our needs and 

t 4 1 he would be the appropriate person then because of 

t 51 his Defense Department experience. 

I invited Mr. Conroy because he 

176; handles external relations community relations 

r s 1 public relations for the holding company and also 

t 9 1 Interfaces with those functions at the operating 

rlommpanies. 

Q 

[ :: j meeting. were 

Now, when Ms. Lewinsky came to this 

t 13 1 from the outse r 

ou treating this meeting, at least 

, were you treating this meeting as 

r 14 1 more of an informational meeting or more of a job 

115) interview or something else? 

I161 A Frankly. both. 

I wanted to be responsive to Mr. 

I :i; Jordan and give her advice as a New Yorker who had 

[ 19 1 some expenence leaving the Government myself and 

[ 20 I also to see if there was a match between what she 

[21 lwanted to do and what I rnP ht have or what we 

r .~~, 22 I mioht be able to offer her a 

r23lcoiirpanies. 

one of the owratina 

1241 0 How did that interview go? 

[251 A It went well. 

Page 17 

Ill 

121 A Okay. 

%Wvell? 

Q Now, you said Mr. Jordan was then? 

. -. 

151 A No. 

161 Q Excuse me. Mr. Conroy. Pardon me. 

171 A Right. 

Q So Is you. Mr. Conroy. Did 

I “, ; anybody else come to the meeting? 

A No. Mr. Duman was invited, but he 

&asoutoftown. 

I121 Q You are saying Duman? 

1131 A Yes. 

Q 

I ::i invited Mr. 

Was there any reason that you 

ri6imeetina? 

Conroy and Mr. Duman to come to the 

. ..I 

[171 - A Yes. 

I181 Q Why? 

A I invded Mr. Duman because of his 

~:~iduties basicallv as chief of staff in the office. .--, 

He routinely interviews people both 

i::iat the entry level and more experienced. and also 

[23 lhe had an extensive background in the government, 

124 1 

Et 

rticularty in the military and Defense 

(251 ParbTIent. 

OlCSmr 

---__~ 

PageUbPagel8 
1295 

esA Richard Halperin, 4/23/98 

Page 19 

Can you describe generalty what you 

izoj -A No. 

Cl 

i:i ; Lewinsky, based on the in ervtew that you had? 

123: 

What was {our, impression of Monica 

A I thouaht she was an enthusiastic 

i 5 i i young person who hzd a good experience for a 

~25; person her age, who was worthy of consideration if 

Page 20 

I11 

[ 2 I we had something to offer. 

Q Did you consider her for your 

1:; secretary position as a result of the interview? 

A Well, it was dear to me that she 

j i &@s, lookin! for an enty level professronal 

s&on ert er In a pub IC relahons agency or on 

[ 9 ; e ckent side and she didnt ’ want to be an 

15 lexecutive assistant. She had done that. 

i :E j u 

0 Based on your intervraw with her an 

P 

on an opening or the availability of a position 

[ 12 : a MacAndrews 8 Forbes, did you make a decision 

[: 3 : about whether Monica Lewinsky was nght for 

t 14 ; MacAndrews 8. Forbes at that bme? 

[IS: A 

[ 1 E : other than 

WetI, since there was no opening, 

my posrtron at Mad\ndrews. and she 

[ 17 ;didnt ’ have any interest in that, it was apparent 

: 18. from the interview Jim Conroy was going to refer 

[ I;: her to Revlon. 

12;: Q 

12:. Revlon? 

Refer her for any particular job at 

A Yes. For a public relations entry 

1;; 1 level job in the public relations area at the 

12 4 : Revlon Compan 

/,c. 

,--. Q dp to this point, I am talking up to 

Page 21 

I . 11. 

[z : the point where you finished the interview and Mr. 

[ 3 : Conroy was going to forward her resume to Revlon, 

[.~*was there anything unusual about the way Ms. 

[ 5 : Lewinsky came to the company or any unusual 

[ 6 influence on you or the company to hrre her in any 

l-:way? 

I?’ Did you notice anything like that? 

c9: A No. 

Q As far as you know did Ms. Lewinsky 

I :! i come back and meet with Mr. Duman? 

1121 A Yes. 

(13: Q Would that have been on or about 

r 14 : January 8th? 

il5j - A Yes. 

i16: Q you left the. office for a bit to go 

11: : on vacatio; duye%,thrs penod. nght? 

113: 

119‘ Q 

;7r; 

Were YOU back bv the Bth? 

L‘.“. A Yes. . 

12:: 0 Did you know that Ms. Lewinsky would 

t---be .-~. -~ meetino with Mr. Duman? 

123: A No. 

[24: Q So obviously 

[?5.if you didnt ’ know that it was i 

ou didnt ’ arrange it 

appening? 

Page 22 

Ii! 

(21 A Cor,ect 

Q Did you speak to Mr. Duman after he 

I : i met with MS Lewinsky? 

LS! A Yes. 

I61 Q 

A 

What did you talk about? 

He told me he had met with Monica 

Ii j Lewrnsky and that he was going to send her resume 

[alto Revlon. 

110: Q Did he tell you what he thought of 

I I I 1 Monica Lewrnsky? 

112: A I dont ’ recall discussing that. 

Q . Did Mr. Duman drscuss wdh you 

i :: j whether he had s 

5 

oken to Vernon Jordan about 

;;;;Monca LeyI;yo: 

0 Did he discuss with you whether he 

i :i; had spoke; to ;t;.ald Perelman? 

[I91 

Q 

~E~Perelman is. 

Why dont ’ you just describe who Ron 

A Ron Perelman P-e-r+Gm-a-n, is 

~::~chairman and chief executiveofficer. ’

Q To your knowledge, does he know 

[f:iVemon Jordan? 

XMAXlUll 

Page 23 

Cl1 

[II A Yes. 

[31 Q What did Mr. Duman say in the 

I 4 Idiscussion with Mr. Perelman? 

[51 A If I could clarify. 

I had two discussions that day with 

176iMr. Duman. The first was informing me that he 

t 9 1 had met with Monica Lewinsky that day, and the 

t 91 second conversation was a conversation in which 

[lo] Jaymie Duman told me that Ronald Per&man had 

[ 111 received a call from Vernon Jordan inquiri 

[ 12 1 the status of Monica Lewinsky and Jaymte -%%taon 

[ 13 1 was asked by Mr. Perelman to see if we could be 

[ 14 1 helpful at Revlon, 

(151 Q 

r 161 he thou 

Did Mr. Duman indicate to you that 

ht there was an 

[ 17 1 contact %e 

hn unusual about that 

A;’“eeN”ohim an SB ’Mr. erelman? 

Cl81 

Q Did you see anythin 

I:zlcontact between Mr. Perelman and 

unusual about 

RA r. Duman? 

[?I1 A No. 

Q 

I%ithis question. do you see an 

And also, I m$ht have asked go 

hrng unusual a 

[: 4 1 the contact between Vernon Jordan and Mr. Perelman 

[zslwhich led to the contact between Perelman and 

Page 24 

111 

[ZlDuman? 

I31 A No. 

Q Did you have any other discussions 

Iijwith Mr. Duman about Monica Lewinsky at that 

[ 6 ] period of tirrn?? 

l7! A January Sth? 

IZi 

Q Yes. - 

A No. 

Q Did you know that Monica Lewinskys ’

i :y i resume was actuall forwarded to Revlon? 

1121 A On t K 

[ I 3 1 that he forwarded it. 

e 8th. I think Jaymie told me 

I::lthat? 

Q Did you hear anything about it after 

1161 A When? 

Q With regard to the resume getting to 

i :i i Revlon and her interviewing. 

I191 A What time frame? 

1.201 Q 

i2li 

Lets ’ say in the next week or so. 

A No. - 

122: Q Did you find out up to the point 

[ 2 3 1 when this broke as an actual news story, did you 

~24 Ifind out that Monica Lewinsky had intervrewed or 

[ 2 5 1 been hired by Revlon? 

-.- 

Page 19 t6 Page 24 OlCStarr 
1296 

XMAXIYSi 

.- 

e?iA Richard Halcwin. 4/23/98 

ill 

r-1 

Page 25 

A NO 

t-1 

I31 a When is the next time you heard 

[ 4 Ianything about Monica Lewinsky? 

15: A 

[6]belieVe it Was. 

On the morning of January 21st. I 

171 Q How did you heaf? 

I91 A There were television reports. 

r iziwatching te 

I pt. in the office e;rty and I was 

vtsron and then I received a call 

[l~lfrom Jim Conro that rnomin 

0 &hen you firs heard the reports I 

I :: i assume you were watching the news when you say ‘

i I 4 1 reports on~lev$~sqn? 

1151 

0 When vou first heard the reports on 

[:76ithe news, what aboutthe reports tip 

A Well it mentioned a Er%tz 

i : ii intern it rnentionedMonica ’ Lewinsky b 

t 2 o 1 mentioned Vernon Jordan, and I 

name it 

im 

rzllthat obviously I had met her. 

rnec7iatety knew 

Q And you made the connection to the 

~::~interviews that ou had? 

I241 A &xi. 

[251 Q Once you heard those reports and you 

- 

Page 26 

[II 

_ [zlgot a phone call, the first phone call was from 

13 1 whom again? 

141 I think you said the first phone 

[ 5 I call may hre esn from Jrm Conroy? 

[61 

[71 Q And he called you? 

191 A Yes. 

Q What did you and Mr. Conroy talk 

( :i i about at that point? 

A He told me that he had heard, I 

1 ii; believe, on the radio a report that Monica 

[ 13 1 Lewinsky was the former White House intern who was 

[ 14 1 introduced by Vernon Jordan to others seeking a 

rlsljob. 

Q After the conversation conversation that you had, 

i :76; that first conversation conversation with Conroy. Conroy. did you call 

[ 13 I anybody else? 

I151 A Yes. 

I201 Q 

A 

Who did you call? 

[II ‘

I called Jayrnie Duman. 

l.l?j Q 

r33!Mr. Duman? 

And what did you speak about with 

A I told him of the report and he told 

i: l i me that Revlon had offered offered her a job. And I asked 

[II 

Page 27 

13 I him whether she had started, and he didnt ’ know. 

Q Did you make any arrangements to see 

i: 1 Duman later that morning? 

15: A I routine1 he and I are wllea ues 

[ 6 1 and work continuously t i rough the day toget % er. so 

[ 7 1 I knew I would see him that morning. 

[91 Q So 

[ 9 1 you when you get r 

ou basically left it, I will see 

o the office; is that fair to 

rlolsay? 

ill1 A Probably. 

[121 Q Did you call anybody else after you 

[ 13 lspoke to Mr. Duman? 

Cl43 A Yes. 

[I51 Q Who is that? 

I161 A I called Howard Gittis. 

I171 Q who is Mr. Gittis? 

I191 A Howard Gittis. G-ii-t-t-i-s. He is 

[ 13 1 our vice chairman and chief administrative 

~zolofficer. 

Q The first question I will ask is why 

izi;did you call Mr. Gittis? 

[231 A Because I knew that Mr. Gittis was 

1: 4 1 scheduled to have breakfast with Vernon Jordan 

(251 that morning. 

Page 28 

::: .^. 

! 5 : Gais? 

Q bd’hat ’ did you talk about with Mr. 

::- A I told Mr. Gittis of the news re 

B 

ort 

ardin ig~ ? Monica Lewinsky and Vernon Jor an, and I 

hrm hat I had intervrewed Monrca Lewinsky 

i 7 jfor a job at MacAndrews and he was unaware of 

rs:that. 

:3: Q What was his response? 

ilC: A He knew nothing about rt. 

And I told him that I wanted to let 

1 ii : him know that because he was having breakfast with 

[ : 3 :Vemon and this was something he needed to know in 

[ :: : advance of that breakfast. 

115: Q Did you make plans to speak with him 

: 16 1 later in the day? 

Ii71 A 

ii3lofficf?. 

I tokl him I would see him in the 

(19: 0 

[ 2 0 I morning? 

Did you call anybody else that 

121: A Yes. 

122‘ Q Who was that? 

I23j 

[24! 

1251 

A Bill Green. 

.Q Who is Mr. Green? 

A Mr. Green is the vice president of 

- 

Page 29 

:z lgovemment affairs and runs our Washin 

I:! 

What did you discuss wrt 3Mr. Green? 

ton office. 

Q 

A I had just wanted to bring him up to 

I 5 i date because he runs our Washington office, so 

[ 6 1 that he would not be su rised to learn that I had 

[ 7 1 known and met Monica p ‘

[9: Q 

ewnsky. 

Just to clarify, I am askin 

~91~0~ called. Implicit in my question rs on 9 

you who 

his 

: 0 j issue. 

_ . 

Im ’ not asking you who you called on 

11 i a million issues. 

. . 

I am sure ypu ma* p lot of 

i 13 ; pnone CalIS. Just so ou unaerstand tnat. 

114: 

[ 15: issue, 

Did ou calran body else about this 

first in t it 3 

A 

e morning 

Yes. One more person, our general 

! i7”; counsel. Barry Schwartz. 

f13’ 

rlsjthat? 

Q What did you relate to him about 

1:s: A He is our wunsel12:: 0 

[zzladvice. 

I dont ’ want you to go into legal 

eneral counsel. I 

- 

Page 30 

1: :should answer that question. I am hap 

I brought him up to date to te P I

y to do it. 

13: 

!: .him - he, too, dtd not know that I had met with 

[ 5: Monica Lewinsky and did not know that Revlon had 

I 6 1 offered her an opportun. 

.Y‘ So I told him o vthe current status 

; 3 i and we were to meet later that momrng with Mr. 

[ 9~ Gittis and with Mr. Stillman. 

llil Q And who is Mr. Stillman? 

11:: A Charles A. Stillman is our outside 

t 12 I counsel. 

r13: Q And he is also representing you this 

I 14 lmoming, correct? 

115; A Correct. 

116: Q So thats ’ the same Mr. Stillman that 

[ 17 : you identified at the beginning of this 

[ 13 : deposition? 

115: A Yes. 

[zc; Q Apin. I-understand the privilege 

r3:land I dont ’ want 0 aet into that. but did vou 

i33 i have a meeting - y&r just described a meeting 

I 3 3: that you agreed to have later on in the morning 

13 4 : wdh several lawyers. 

125: Did you have that meeting’ 

acaarr -___ ~~ . _-_ _~ 

Page 25 to Page 30 
Page 31 

[I: 

I:: A Yes. 

0 

i: 1 take anv action? 

As a result of that meeting, did you 

isj ’ A Well at that 

[ 6 1 anythrng we did privileged, iif 

int I would consider 

cause I did nothrng. 

[ 7 1 It was m the hands of our attome 

[81 Q Did MacAndrews c Forbes, to your 

I 91 knwae. take anv action - well. lets ’ out it 

[iojthisway: * 

. 

Did MacAndrews 8 Forbes send a 

1 :i i letter to Monica Lewinsky or ask Revlon to send a 

I 13 I letter to Monica Lewinskv with reoatd to her 

i14jempioyment offer? . 

A I subsequently learned that Revlon 

/:z;sent a Letter to Ms. Lewinsky through her 

c 17 I attorney. 

I181 Q 

I191 A 

What did that letter say? 

I dont ’ have that letter. 

Q Do you know what the substance of 

[:yithat letter was in general? 

[22] A I ‘ havent ’ seen it, Tom. 

Q 

j::iunderstandin 

As far as that letter, was it your 

that the letter was in essence 

I I 5 J notifyrng Ms. e ewrnsky that the offer had been 

1297 

Richard Halperin. 4/23/98 XMAX(M1 

Page 34 

[ 3 ldoing it in essenc& for two reasons, to give her 

[ 3 I advice and to also interview her and consider her 

[ 4 J as a possible candidate at either MacAndrews or 

I 5 1 Revlon or one of your companies; IS that correct? 

161 A Yes. 

Q You did that based upon the call 

ii i that you got from Vernon Jordan? 

[91 -A Yes. 

Q 

!:iiVemon Jordan you considered hat o be a 

And the call that pu got from 

[ 12 1 recommendation of Monrca Lewrnsky. correct? 

1131 A Absolutely. 

1141 Q 

rlslthat right? 

She was an entry level employee; is 

[I61 A Yes. 

[I71 Cl How many entry level employees have 

rlelyou interviewed in the last year? 

1191 A Well. I interview secretaries that 

izojwould work at the holding company any secretary 

rzllthat would go into the chairmans ’ office or any of 

rzz]our senior executives I would meet, and in terms 

[z3]0f ent level positions, its ’ not on throu h 

[zs~the ho ?I. ng company that I would 

rzslpeople. 

lZe mee?ing 

(11 

Page 32 

tz J retracted? 

I31 A Yes. 

Q And thats ’ what you had told us when 

fziwe tajked last time, right? 

[6: A Yes. - 

Q Your understanding now is still 

Ii ~conststent with that? 

191 A Yes. 

Q Is Vernon Jordan on the board of 

:: jdirectors of Revlon Mad\ndrews 8 Forbes, or both? 

121 A Revion. 

13; Q Has he ever been on the board of 

14 1 MacAndrews? 

15; A I dont ’ know that MacAndrews had 

16~outMe directors. 

17: I believe he was on the board of 

13 !Revlon. Incorporated and Revlon Group, 

19 1 Incomrated, which is a holding company that 

20 1 prevrously held Revlon, Inc. 

-2, ] I dont ’ believe MacAndrews 8 Forbes, 

s? 1 the utbmate parent, had outside directors. 

23: Q So, to your knowledge, the answer is 

3 4 1 no, he was not on any board that was the 

2 5 1 MacAndrews 8 Forbes board? 

Page 33 

II 1 

.-1 

12: A To my recollection. no, but I could 

[ 3 1 certainty check the records. 

[4; Q Thats ’ fine. 

As far as the phone call on the 1 lth 

t z i of December that you had with Vernon Jordan, you 

I 7 I went ahead and described it for us. igj Could 

I 9 1 walk us through I 

ou just, as bestpu can, 

he conversation 

Who called whom? Did you call him 

~:~jordidhecallyou? 

A I had spoken with Vernon the day 

I :: 1 before on an unrelated matter. And then I believe 

: 14 I he called me that day, and it was a short 

: i 5 J conversation. 

And as I previous 

i :7”; certain whether or not I had !l 

stated I am not 

e lette; in front 

113 lof me But it was a short call. he described 

[ I 3 J Monica Lewinsky briefly to me and encouraged me to 

: z a 1 meet wrth her and give her advice and thats ’ what 

i2:jit was 

17, ‘Lb.. And what I said was I would be happv 

:33!to do rt. 

_ 

Q Now, when you met subsequently with 

i z l i Monica Lewinsky, you indicated to us that you were 

Page 35 

Ill 

[Zl 

r31cant ’ tell 

To answer your question exactly, I 

r 4 1 unusual ii 

ou how many of us, but its ’ not 

r me to even meet an entry level person. 

[51 Q You have indicated to us that at the 

[ 6 1 time you interviewed Monica Lewinsk 

Illwas ’ an oyin 

?&ht 

for a secretary, nght. 1 

that there 

(RI ,..> 

-Q 

_ 

I91 

[ 1 o 1 Mr. Halperin? 

What has happened to that opening, 

1111 

r 12 ! my previous secreta 

A MY *=$aay;;~g$;$;geek 

[ 13 Ifrom California and s e called me over the 

r 14 weekend. so that has been filled. She is coming 

ilsjback. 

;:76;for that job! 

1181 

0 

I:Z;interviews? 

1211 4 

Had you interviewed any other people 

Yes. 

And did you participate in those 

Yes. 

You indicated that you called Bill 

if:iGreen. 

Q 

Dii he a pear to know about Monica 

ISzjLewinsky and the P act that she had interviewed at 

Page 36 

[II 

[ 3 I your company? 

(31. -A - I dont ’ recall: 

0 

i : 1 called him. 

Again. tell me the reason why you 

A Because he runs our Washington 

i; i office and I just, this was really a Washington 

r e 1 story. I wanted him to be informed that this was 

[ 9 1 an issue that was 

[ 10 1 the news world, In 3 

oing to directly impact us in 

he news cycle. 

And I wanted him to be informed 

i :: ; not informed b 

and 

r 13 1 involved with d 

a third party that we were ’ 

Q 

Onlca Lewinsky. 

i : l i Vernon Jordan 

Since your December 11 th call with 

have you had any communication with 

r 16 1 Vernon Jordanat ’ all? 

[I71 A No. 

[I81 Q That would indude not only 

[ 19 I telephone calls or conversations, but also written 

[ 20 1 communication? 

(211 A Correct. 

[221 Q And the answer is still no? 

(231 A Correct. 

[241 MR. BINHAK: 

(251 MR. BIENERT: 

Thank you. 

Thats ’ all I 

Page 31 to Page 36 

- 

olcstafl 
1298 

asA Richard Halperin, 4/23/98 

i161 

1171 

llS1 

1191 

l2Ol 

[Zll 

122: 

1231 

[24! 

I25: 

Page 38 

;1: 

ii i STATE 

CERTIFICATE 

0F NEW YORK ) 

D”NT% NEW YORK ) 

I. ANNETTE FORBES, a Certified 

8~~~~~b~~t~~~~~~~~~~nd 

York, do hereby certii that the 

fore oin Deposition of the witness 

RI&A& E. HALPERIN taken at the time 

and place aforasaid, is a true and 

rozst transcnptron of my shorthand 

I further cert. 

T 

that I am 

neither counsel or nor related to any 

party to said action, nor in any wise 

interested in the result or outcome 

il5: 

:23: 

.-. ~ 

:--. ,-_I. 

.-- ,_1*. 

thereof. 

IN WITNESS WHEREOF, I have 

hereunto set my hand this 28th day of 

April, 1998. 

ZMAZITfrl 

Page 39 

I:-” 

r:3i 

[II! 

1151 

[i6; 

1::: 

iI?: 

[:9: 

,?^, 

.--. 

Page 37 to Page 39 

01298 
1289 

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

29D-OIC-LR-35363 

Continuauon of OK-302 of RICHARD HALPERIN ,On 3/27/98 *page S 

The second call he made was to JAYMIE DURNAN, at which 

time he learned from DURNAN that LEWINSKY had been offered 

employment by REVLON. 

He then called HOWARD GITTIS, General Counsel, MFH, 

because he was aware GITTIS had an appointment with JORDAN in New 

York that very day to meet for breakfast. He told GITTIS there 

was a story on television that VERNON JORDAN had helped MONICA 

LEWINSKY, a former White House intern linked to President 

CLINTON, get a job with REVLON. GITTIS said he had heard the 

news, but was not aware there was a connection between LEWINSKY 

and MFH. 

HALPERIN did not attend the breakfast with GITTIS and 

JORDAN, nor did he attend the usual MFH executive breakfast that 

morning. 

The last conversation HALPERIN has had with JORDAN 

on December 11, 1997. He has.not received any written 

correspondence from JORDAN. 

was 

On the morning the news reported the LEWINSKY-REVLON 

connection, a meeting was called at MFH with upper level 

executives along with the corporate counsel, CHARLES STILLMAN. 

It was decided that REVLON would suspend the hiring process for 

LEWINSKY. A reference to WILLIAM GINSBURG, attorney for 

LEWINSKY, was seen in the press. They located his law office the 

same day and faxed a letter advising him that LEWINSKY's offer of 

employment was being suspended. There was no response from 

GINSBURG's office. 

LEWINSKY's employment offer was subject to checking her 

references. Telephone calls were made to her reference at the 

Pentagon. When doing lower level hiring, MFH and their holdings 

always check references and do some background investigation. 

Letters of acceptance sent to newly hired employees are 

conditional on acceptable reference checks. 

, 

HALPERIN was aware of the situation with WEBSTER 

HUBBELL and his legal problems which occurred after he was 

retained for his services. When asked his opinion of this 

matter, HALPERIN said it had been an unpleasant experience for 
1290 

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

29D-OIC-LR-35063 

Continuation of OIC-302 of RICHARD HALPERIN . On 3/27/‘98 .Page 6 

the company; however, this matter did not come to mind in regard 

to LEWINSKY and the JORDAN referral. According to HALPERIN, MFH 

was not "gun shy" about dealing with LEWINSKY, in view of the 

fact that JORDAN also referred HUBBELL for employment. 

HALPERIN has not been contacted by anyone at the White 

House or ROBERT BENNETT. There is no defense agreement with the 

White House. 
1291 

Richard Halperin, 4/23/98 

OIC Deposition 

Page 1 to Page 39 

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 
1292 

Richard Halperin, 4123198 xlMx(l/l ) 

Page 1 

::: 

I-. 

,-a 

:;I ----_---------------x 

:4:1X RE: GRAND JURY INVESTIGA1:ON 

.c,--------------------~ ,-. 

161 

17: 

!B! DEPOSITION DEPOSITION of RICHAR!Z RICHAR!Z f. HALPERIN, HALPERIN, held at 

[9]the offxes of Messrs. Messrs. Stiliman, Stiliman, Frxdman Frxdman L Shaw, 

!:0]425 !:0]425 Park Avenue, Avenue, New York, Heu York 10022, on 

!:l]Thursday, !:l]Thursday, Aprli 23, 1998,. caaencing caaencing at 9:15 

::2]o'clock ::2]o'clock a.m.. before Annette Annette Forbes, Forbes, a Certified Certified 

;:3]Shorthand ;:3]Shorthand (Stenotype) (Stenotype) Reporter Reporter and Notary PublLc 

:14lulc.'.;n and for the State of Seu York. 

iI51 

i161 

il71 

I181 

iI91 

1201 

:211 

I221 

:231 

:241 

[25] 

Page 4 

1;; 

: 2 1 reporter thus morning. and a transcnpt will be 

: 3 I made that will ultimately be presented to the 

! 4 I rand ju whrch is investigating these matters in 

;;;%Iashing%n. D.C. 

Do you understand that? 

17: A Yes. 

I81 Q Everything as t said. that you say 

! g]wilI be taken down, and t at s Important for a 

[ :o 1 couple of reasons. 

First, you have a Fii Amendment 

iii; right not to say anything 

i : 3 1 incriminate you. 

that may tend to 

!i4: Second. since eve hrng IS taken 

I :5]down, we will have an accura T e record of what has 

rlslbsen said todav. 

And you should just be aware that it 

i :i i is against Federal law to knowingly make a 

[ I 9 1 misstatement of material fact dunng the course of 

:201tb deposition. That can be perjury or other 

rtl~cnmas. and those felonies are punrshabie by law. 

1221 Do you understand that? 

[231 A Yes. 

[241 Q In a normal deposition you might be 

t 2 5 j provided a transcript. but because we are 

Page 2 

!;;APPEARANC s: 

i3i OFFICE d F THE INDEPENDENT COUNSEL 

1001 Penns lvania Avenue, N.W. 

!41 Suite 4QOyNorth 

i51 

Washington. D.C. 20004 

BY: THOMAS H. BIENERT. JR., ESQ. 

:61 Associate lnde “dent Counsel 

STEPHEN BINHA/? ESQ. 

Associate Independent Counsel 

[l? 

Page 5 

:71 

!3! 

:51 . 0: ::. 

*I ::q, 

a*... 

:131 

:14j 

'151 

:161 

-._. 

zaj 

~‘9; :;, .-i! .-. , 

.--, ._^> 

I--! 

::3j 

::4; 

;r51 

12 ~conducting this deposition in lieu of grand jury 

I 3 1 teshmony. we will not be providing a transcript 

r 4 I of thus momin 

t 51 providing that s 

s ‘ deposition and we will be 

ranscript to the grand jury and 

[ 6 lmll be reading it for them. 

171 Normally if you were to testii 

t 8 ~before a grand jury, there are rules of secrecy 

[glforthe grand ju 

r 

. 

r101 What hose mean is that the court 

I i 1 I reporter. Mr. Bieneti and I are bound bv those 

Page 3 Page 6 

1. / 

_-, 

~zIRICHARD E. HALPERIN.calledas 

i3i a witness, having been first duly sworn by 

:4j Annette Forbes, a Notary Public of the 

:5: State of New York, was examined and 

61 ‘ testified as follows: 

i 7 ; EXAh0NATION 

.I ‘ BY MR. BINHAK: 

y: Cl Good momin 

7 ‘ 01 Why dont ’ you 

f i I i spell it for the record. 

sta 8, 

Mr. Halperin. 

e your name and 

A Richard E. Halperin. 

[:I 

i z I part of that trial 

:31- Do you understand that? 

I41 A -Yes. 

Q Also, there is a reporting function 

I z lof the Oftice of Independent Counsel and as part 

r 7 J of that reportins function. the office will 

r 8 I prepare or may prepare a report, final report of 

[ 9 J all the work that the office did, a more specific 

I 1 o 1 report of this. Excerpts of your transcript may 

t 11 J appear in that report. 

1121 Do you understand that? 

[I31 A -Yes. 

[I41 Q Finally, Mr. Bienert and I work with 

[ 15 ] several investigators and agents. You m’ 

I i 6 I met one of them last time we were here. 

ht have 

p ‘ hose 

[221 A Yes. 

I231 Q You understand the Fifth Amendment 

[ 2 4 I right that I~P$I~~~I to you before, nght? 

[25i 

Page 1 to Page 6 
.- 1293 

asA Richard Ha&win, 4/23!98 XMAXW’Z) 

Page 7 

!11 

[:I Q We are atso here at your attorneys ’

[3 ~offrce and you are represented by an attorney, 

r4iCOTTeC1? 

i5i A Yes. 

Q Can you state for the record who 

l;ithat attorney is? 

A 

~~~S-t-G+-m-a-n. 

Charles A Stillman, 

i17i 

1181 

A -Yes 

Q ThelastthingIwillsayisifI 

uestron that you dont ’ understand and 

0 darify. phase ask me to, I will 

(11 

Page 8 

121 Q You understand everything I said, 

[ 3 land you are willing to proceed this morning under 

r 4 lthe rules that I have iust set out? 

i5i A Yes. - 

[Cl Q Why dont ’ you just explain, please. 

17 1 the position you have and where you work and how 

r 8 llono vou have been workino there and the duties 

i 9 i yocriave rde#;gg;;t$ is executive vice 

i :t 1 resrdent and speaal counsel to the chairman at 

[ 12 1 & acAndrews 8 Forbes Holdings. Incorporated. We 

[ 13 1 are a diversified hotding company based in 

~14 IManhattan. And I have been employed here since 

[ls;February of 1994. 

1161 Q What are your duties as executive 

[ 17 I vice president and special counsel, just 

; I 3 1 generally? 

[19i A Generally, I handle government 

[~olrelabons. I handle real estate and special 

121 lprotects and special assignments as they arise. 

;:2: Cl Why dont ’ you ust ‘ give a sort of 

[ 2 3 1 brief thumbnail sketch of Ma CA ndrews 8 Forbes, 

I141 You said its ’ a holding company? 

[25]Just tell us - 

Page 9 

Ill 

A We are a diversified holding 

Iiicomoany. Our largest company is a company called 

(4 j Revion. a consumer products company based here in 

rs]New York. 

if i thrift In California. CALFED. formerly 

We have an interest in a ia? 

rrst 

[ 8 1 Nattonwide. 

r:ziC’ 

We have an interest in Consolidated 

P 

called MacAndrews 

[III& 

\ ::; in a company call Panavision in the entertainment 

[ I 4 1 business. 

We have an interest in Meridian 

~:~~Sports. which is a Master Craft Boat Compan 

1171 0 Do you have an interest in Co z man? 

A We lust divested. We had a 

[ :ii controlling interest tn the Coleman Company, which 

r:olis based n Wichita. Kansas. 

We sold our interest in the Sunbeam 

IziiCompany and it recently closed on that 

[ 2 3 1 transaction. 

Q 

~~~~Forbes have? 

How many employees does MacAndrews B 

Page IO 

Ii. 

[2: A About 170. 

!?I Q Of those 170. about how many of 

[ 4 1 these are senior people. executives7 

15: A Maybe 30. 

16: Q As part of your job at MacAndrews 8 

;7 1 Forbes, do you have occasion to deal with outside 

rs~counsel? 

[91 A Yes. 

110: 0 

I 1: I Jordan? 

Do you know a gentleman named Vernon 

r12: A Yes. 

Q Does he have a relationship with 

i :: j MacAndrer ayFobes in a professronal capacity? 

1151 

111 

Q 

Page 11 

i:&ith Mr. Jordan? 

Do you have a personal relationship 

[4! A I know him well. 

Q 

t z ; Do YOU see him sociallv at all? 

Do you have a social relationship? 

[71 A No. - 

[8! Q In a typical one-month period, about 

r 9 1 how manv times on averaoe. and I am iust askino 

[ ioi just an ap’ 

[ 111 usually ta ii 

roximate. aboul how many ti~sGfo~j;ou ‘

to Vernon Jordan? 

[El A Probably eve other month. 

[13i 0 1 

rl41that might come up in a conversation 

And what ma ers are p~;~y~F~rs 

te’ 

[ 15 I and Vernon Jordan? 

[16: A I my not have mentioned, sir, in my 

I 17 I explanation of my uties that I am also the 

[ 1s ! resident of numerous foundations, MacAndrews 8 

[ 191 I-! orbes. Revlon Foundation. 

[ZOj So I will speak to Vernon about 

[21 lcharitable contributions. I will talk to him 

[zi labout community relations and I will talk to him 

(23 I about ovemment relations and sometimes I will 

[241talk to 8. im about tegal matters. 

[25; Q Since November of 1997, can you put 

Page 12 

[ -7 Ia number on how many times you have spoken to 

I 3 1 Vernon Jordan? 

141 A I could estimate two or three. 

[5: Q Of those times that 

I 6! him, did you see him in person or dy 

ou spoke to 

[ 7 J him on the tele hone? 

Id you talk to 

13; A 

l9! Q 

6r-r the telephone. 

Of those meetings, did you ever have 

lojany discussions with him about an individual named 

111 Monica Lewinsky? 

I121 A Yes. 

1131 Q Why dont ’ you tell us what the 

I 14 ;discussions,, as best 

I 15 I Monica Lewrnsky in 

ou can remember, were about 

t K at tekphone call. 

116: A s-he . --I 

-Q 

--.-. 

il i that would 

And if you can put a date on it. 

i191 

be meat. 

A “On or about December llth, I 

[za!received a letter from Monica Lewinsky that 

~2 I! referred to Vernon Jordan and Vernon had called 

rz! me to tell me that I would be getting a letter and 

[z 3! resume from Monica Lewinsky, who was a White House 

[ 2 4 I intern formerly and currently at the Defense 

j 2 5 I Department who was relocating to New York and 

Page 7 to Page 12 OlCStan 
.- 1294 

asA Richard Halperin, 4/23198 

Page 13 

[I! 

(2! looking for opportunities in the public relabons 

13 Iworld at the entry level. 

I cant ’ recall 

Izi had Ms. Lewinskys ’ le tf 

recisely whether I 

er at hand when Vernon 

[6]called. I may have. 

Q But if 

1; i letter receiving the p 

ou did, receiving the 

[ 9 J at the same time? 

K one call occurred roughly 

r101 A Roughly the same time. 

[ill Q Wnhn a few days of each othen 

c12: A Yes. 

[131 Q Lets put aside the letter for a 

[ 14 1 second now 

When you spoke to Vernon Jordan and 

i :z i he had told you about Ms. Lewinsky and the fact 

[17tthat she wanted to relocate to N+w York, did he 

[ 1 e 1 ask you to act on her in any partlwbr way? 

A Well, he Saki she was a bright young 

i:ziwornan who was energetic and enthusiasbc and 

t2 11 wanted me to basicall 

(22 lrelocating to New Yo x 

give her advice on 

and the vanous 

r23lopportunrtii in New York, encouraged me to meet 

i24 j&h her. 

I251 Q Was there anything unusual about 

Page 16 

Ill 

0 Wh 

iSlat that meeting an J 

dont ’ you describe what happenec 

14’ A 

when rt hap pened. of course. 

ii j recoltection. 

Perhaos vou cou d refresh mv . I 

[Cl MR. BIENERT. Could it have 

[71 been around December Bth? 

[El THE WITNESS: Yes. 

[91 Q Does that sound about right? 

[lOI A Yes. 

1111 Q 

112lmeeting? 

December 8th. did you have a 

1131 A Yes. I met with her and asked Jim 

ii4 i Conroy. our senior vice president of public 

ilsjaifairs; to join us. 

[I61 _ Q First of all, where was that 

[17lmeeting? 

[I81 A 

0 

In my office in New York City. 

1191 

1201 A 

What is the address of your offoe? 

35 East 62nd Street. 

iZ;in the morning or 

Q W..y$$e;fthe;~tiw was 

A I believe it was in the morning, but 

I::!perhaps I shoutd check that. 

(251 Q I dont ’ think tt% very important. 

Page 14 

- [ :: 1 that the request that Vernon Jordan was asking 

13 1 

r 4 1 b 

oui in light of your general experience as a 

usrness executive, In general, and,your business 

[ 5 1 dealings wih V;$on Jordan In pamculafl 

161 

0 Did he ask you to work on any 

iii particular kind of timetable with Ms. Lewinsky? 

191. A No. 

Q At the time you got this call from 

[:?;Mr. Jordan were you looking for anybody in 

r 12 1 particular or were you looking to fill an 

r 13lparticular rrhoro;, at MacAndrews 8 F orbes? 

I141 

(15: Q 

rl6;which ones. 

Why dont ’ you describe which one or 

A M secretary of seven years had 

I :~;recently resigne d and I was looking to re lace 

[ ;;; ;;r, and that was the specrfic job I was tl!inking 

[LL 

Q 

ifiithat openina? 

Would Vernon Jordan have known about 

.~~_ 

123: A- No. 

Q Were there an other specific 

15: i openings that you knew abo llr at that time? 

Page 15 Page 18 

[I! 

r2: 

13; 

$ $tey,acAndrews? 

I;: 

A No. 

Q Is it unusual for MacAndrews 8 

16: Forbes, people, executives there to intervrew 

17 1 peo le even though there is not a s 

[ 9 1 at hf acAndrews ,& Forbes th$t may K$%aW? 

r ythe pe=o”Aymop~ns??gfy. someone hat 

I :? i ability we will meet them with an eye to either 

[ 12: referring them somewhere. its ’ not unusual for us 

[13lto meet a 

r 

rson who comes highly recommended. 

And Im ’ not meaning to suggest that 

i : t ; Ms. Lewinsky would necessarily have been 

[ 16 j app~Op&te or inapprOpriate for the SeCIt%~S 

[l~jposrtion. Im ’ just asking the general quesbon, 

[13lyou unde%tanotit;t, ’ nght? 

[19i 

0 

~~~~1 just said? 

Your answer is the same, given what 

[r:: A Yes. 

I231 0 

[ 2 4 ! Ms. Lewinsky? 

Did you get a chance to meet with 

(25; A Yes, I did. 

ii, 

I: i match 

So I thought he might be able to 

Ms. Lewinskys ’ abilitiis with our needs and 

t 4 1 he would be the appropriate person then because of 

t 51 his Defense Department experience. 

I invited Mr. Conroy because he 

176; handles external relations community relations 

r s 1 public relations for the holding company and also 

t 9 1 Interfaces with those functions at the operating 

rlommpanies. 

Q 

[ :: j meeting. were 

Now, when Ms. Lewinsky came to this 

t 13 1 from the outse r 

ou treating this meeting, at least 

, were you treating this meeting as 

r 14 1 more of an informational meeting or more of a job 

115) interview or something else? 

I161 A Frankly. both. 

I wanted to be responsive to Mr. 

I :i; Jordan and give her advice as a New Yorker who had 

[ 19 1 some expenence leaving the Government myself and 

[ 20 I also to see if there was a match between what she 

[21 lwanted to do and what I rnP ht have or what we 

r .~~, 22 I mioht be able to offer her a 

r23lcoiirpanies. 

one of the owratina 

1241 0 How did that interview go? 

[251 A It went well. 

Page 17 

Ill 

121 A Okay. 

%Wvell? 

Q Now, you said Mr. Jordan was then? 

. -. 

151 A No. 

161 Q Excuse me. Mr. Conroy. Pardon me. 

171 A Right. 

Q So Is you. Mr. Conroy. Did 

I “, ; anybody else come to the meeting? 

A No. Mr. Duman was invited, but he 

&asoutoftown. 

I121 Q You are saying Duman? 

1131 A Yes. 

Q 

I ::i invited Mr. 

Was there any reason that you 

ri6imeetina? 

Conroy and Mr. Duman to come to the 

. ..I 

[171 - A Yes. 

I181 Q Why? 

A I invded Mr. Duman because of his 

~:~iduties basicallv as chief of staff in the office. .--, 

He routinely interviews people both 

i::iat the entry level and more experienced. and also 

[23 lhe had an extensive background in the government, 

124 1 

Et 

rticularty in the military and Defense 

(251 ParbTIent. 

OlCSmr 

---__~ 

PageUbPagel8 
1295 

esA Richard Halperin, 4/23/98 

Page 19 

Can you describe generalty what you 

izoj -A No. 

Cl 

i:i ; Lewinsky, based on the in ervtew that you had? 

123: 

What was {our, impression of Monica 

A I thouaht she was an enthusiastic 

i 5 i i young person who hzd a good experience for a 

~25; person her age, who was worthy of consideration if 

Page 20 

I11 

[ 2 I we had something to offer. 

Q Did you consider her for your 

1:; secretary position as a result of the interview? 

A Well, it was dear to me that she 

j i &@s, lookin! for an enty level professronal 

s&on ert er In a pub IC relahons agency or on 

[ 9 ; e ckent side and she didnt ’ want to be an 

15 lexecutive assistant. She had done that. 

i :E j u 

0 Based on your intervraw with her an 

P 

on an opening or the availability of a position 

[ 12 : a MacAndrews 8 Forbes, did you make a decision 

[: 3 : about whether Monica Lewinsky was nght for 

t 14 ; MacAndrews 8. Forbes at that bme? 

[IS: A 

[ 1 E : other than 

WetI, since there was no opening, 

my posrtron at Mad\ndrews. and she 

[ 17 ;didnt ’ have any interest in that, it was apparent 

: 18. from the interview Jim Conroy was going to refer 

[ I;: her to Revlon. 

12;: Q 

12:. Revlon? 

Refer her for any particular job at 

A Yes. For a public relations entry 

1;; 1 level job in the public relations area at the 

12 4 : Revlon Compan 

/,c. 

,--. Q dp to this point, I am talking up to 

Page 21 

I . 11. 

[z : the point where you finished the interview and Mr. 

[ 3 : Conroy was going to forward her resume to Revlon, 

[.~*was there anything unusual about the way Ms. 

[ 5 : Lewinsky came to the company or any unusual 

[ 6 influence on you or the company to hrre her in any 

l-:way? 

I?’ Did you notice anything like that? 

c9: A No. 

Q As far as you know did Ms. Lewinsky 

I :! i come back and meet with Mr. Duman? 

1121 A Yes. 

(13: Q Would that have been on or about 

r 14 : January 8th? 

il5j - A Yes. 

i16: Q you left the. office for a bit to go 

11: : on vacatio; duye%,thrs penod. nght? 

113: 

119‘ Q 

;7r; 

Were YOU back bv the Bth? 

L‘.“. A Yes. . 

12:: 0 Did you know that Ms. Lewinsky would 

t---be .-~. -~ meetino with Mr. Duman? 

123: A No. 

[24: Q So obviously 

[?5.if you didnt ’ know that it was i 

ou didnt ’ arrange it 

appening? 

Page 22 

Ii! 

(21 A Cor,ect 

Q Did you speak to Mr. Duman after he 

I : i met with MS Lewinsky? 

LS! A Yes. 

I61 Q 

A 

What did you talk about? 

He told me he had met with Monica 

Ii j Lewrnsky and that he was going to send her resume 

[alto Revlon. 

110: Q Did he tell you what he thought of 

I I I 1 Monica Lewrnsky? 

112: A I dont ’ recall discussing that. 

Q . Did Mr. Duman drscuss wdh you 

i :: j whether he had s 

5 

oken to Vernon Jordan about 

;;;;Monca LeyI;yo: 

0 Did he discuss with you whether he 

i :i; had spoke; to ;t;.ald Perelman? 

[I91 

Q 

~E~Perelman is. 

Why dont ’ you just describe who Ron 

A Ron Perelman P-e-r+Gm-a-n, is 

~::~chairman and chief executiveofficer. ’

Q To your knowledge, does he know 

[f:iVemon Jordan? 

XMAXlUll 

Page 23 

Cl1 

[II A Yes. 

[31 Q What did Mr. Duman say in the 

I 4 Idiscussion with Mr. Perelman? 

[51 A If I could clarify. 

I had two discussions that day with 

176iMr. Duman. The first was informing me that he 

t 9 1 had met with Monica Lewinsky that day, and the 

t 91 second conversation was a conversation in which 

[lo] Jaymie Duman told me that Ronald Per&man had 

[ 111 received a call from Vernon Jordan inquiri 

[ 12 1 the status of Monica Lewinsky and Jaymte -%%taon 

[ 13 1 was asked by Mr. Perelman to see if we could be 

[ 14 1 helpful at Revlon, 

(151 Q 

r 161 he thou 

Did Mr. Duman indicate to you that 

ht there was an 

[ 17 1 contact %e 

hn unusual about that 

A;’“eeN”ohim an SB ’Mr. erelman? 

Cl81 

Q Did you see anythin 

I:zlcontact between Mr. Perelman and 

unusual about 

RA r. Duman? 

[?I1 A No. 

Q 

I%ithis question. do you see an 

And also, I m$ht have asked go 

hrng unusual a 

[: 4 1 the contact between Vernon Jordan and Mr. Perelman 

[zslwhich led to the contact between Perelman and 

Page 24 

111 

[ZlDuman? 

I31 A No. 

Q Did you have any other discussions 

Iijwith Mr. Duman about Monica Lewinsky at that 

[ 6 ] period of tirrn?? 

l7! A January Sth? 

IZi 

Q Yes. - 

A No. 

Q Did you know that Monica Lewinskys ’

i :y i resume was actuall forwarded to Revlon? 

1121 A On t K 

[ I 3 1 that he forwarded it. 

e 8th. I think Jaymie told me 

I::lthat? 

Q Did you hear anything about it after 

1161 A When? 

Q With regard to the resume getting to 

i :i i Revlon and her interviewing. 

I191 A What time frame? 

1.201 Q 

i2li 

Lets ’ say in the next week or so. 

A No. - 

122: Q Did you find out up to the point 

[ 2 3 1 when this broke as an actual news story, did you 

~24 Ifind out that Monica Lewinsky had intervrewed or 

[ 2 5 1 been hired by Revlon? 

-.- 

Page 19 t6 Page 24 OlCStarr 
1296 

XMAXIYSi 

.- 

e?iA Richard Halcwin. 4/23/98 

ill 

r-1 

Page 25 

A NO 

t-1 

I31 a When is the next time you heard 

[ 4 Ianything about Monica Lewinsky? 

15: A 

[6]belieVe it Was. 

On the morning of January 21st. I 

171 Q How did you heaf? 

I91 A There were television reports. 

r iziwatching te 

I pt. in the office e;rty and I was 

vtsron and then I received a call 

[l~lfrom Jim Conro that rnomin 

0 &hen you firs heard the reports I 

I :: i assume you were watching the news when you say ‘

i I 4 1 reports on~lev$~sqn? 

1151 

0 When vou first heard the reports on 

[:76ithe news, what aboutthe reports tip 

A Well it mentioned a Er%tz 

i : ii intern it rnentionedMonica ’ Lewinsky b 

t 2 o 1 mentioned Vernon Jordan, and I 

name it 

im 

rzllthat obviously I had met her. 

rnec7iatety knew 

Q And you made the connection to the 

~::~interviews that ou had? 

I241 A &xi. 

[251 Q Once you heard those reports and you 

- 

Page 26 

[II 

_ [zlgot a phone call, the first phone call was from 

13 1 whom again? 

141 I think you said the first phone 

[ 5 I call may hre esn from Jrm Conroy? 

[61 

[71 Q And he called you? 

191 A Yes. 

Q What did you and Mr. Conroy talk 

( :i i about at that point? 

A He told me that he had heard, I 

1 ii; believe, on the radio a report that Monica 

[ 13 1 Lewinsky was the former White House intern who was 

[ 14 1 introduced by Vernon Jordan to others seeking a 

rlsljob. 

Q After the conversation conversation that you had, 

i :76; that first conversation conversation with Conroy. Conroy. did you call 

[ 13 I anybody else? 

I151 A Yes. 

I201 Q 

A 

Who did you call? 

[II ‘

I called Jayrnie Duman. 

l.l?j Q 

r33!Mr. Duman? 

And what did you speak about with 

A I told him of the report and he told 

i: l i me that Revlon had offered offered her a job. And I asked 

[II 

Page 27 

13 I him whether she had started, and he didnt ’ know. 

Q Did you make any arrangements to see 

i: 1 Duman later that morning? 

15: A I routine1 he and I are wllea ues 

[ 6 1 and work continuously t i rough the day toget % er. so 

[ 7 1 I knew I would see him that morning. 

[91 Q So 

[ 9 1 you when you get r 

ou basically left it, I will see 

o the office; is that fair to 

rlolsay? 

ill1 A Probably. 

[121 Q Did you call anybody else after you 

[ 13 lspoke to Mr. Duman? 

Cl43 A Yes. 

[I51 Q Who is that? 

I161 A I called Howard Gittis. 

I171 Q who is Mr. Gittis? 

I191 A Howard Gittis. G-ii-t-t-i-s. He is 

[ 13 1 our vice chairman and chief administrative 

~zolofficer. 

Q The first question I will ask is why 

izi;did you call Mr. Gittis? 

[231 A Because I knew that Mr. Gittis was 

1: 4 1 scheduled to have breakfast with Vernon Jordan 

(251 that morning. 

Page 28 

::: .^. 

! 5 : Gais? 

Q bd’hat ’ did you talk about with Mr. 

::- A I told Mr. Gittis of the news re 

B 

ort 

ardin ig~ ? Monica Lewinsky and Vernon Jor an, and I 

hrm hat I had intervrewed Monrca Lewinsky 

i 7 jfor a job at MacAndrews and he was unaware of 

rs:that. 

:3: Q What was his response? 

ilC: A He knew nothing about rt. 

And I told him that I wanted to let 

1 ii : him know that because he was having breakfast with 

[ : 3 :Vemon and this was something he needed to know in 

[ :: : advance of that breakfast. 

115: Q Did you make plans to speak with him 

: 16 1 later in the day? 

Ii71 A 

ii3lofficf?. 

I tokl him I would see him in the 

(19: 0 

[ 2 0 I morning? 

Did you call anybody else that 

121: A Yes. 

122‘ Q Who was that? 

I23j 

[24! 

1251 

A Bill Green. 

.Q Who is Mr. Green? 

A Mr. Green is the vice president of 

- 

Page 29 

:z lgovemment affairs and runs our Washin 

I:! 

What did you discuss wrt 3Mr. Green? 

ton office. 

Q 

A I had just wanted to bring him up to 

I 5 i date because he runs our Washington office, so 

[ 6 1 that he would not be su rised to learn that I had 

[ 7 1 known and met Monica p ‘

[9: Q 

ewnsky. 

Just to clarify, I am askin 

~91~0~ called. Implicit in my question rs on 9 

you who 

his 

: 0 j issue. 

_ . 

Im ’ not asking you who you called on 

11 i a million issues. 

. . 

I am sure ypu ma* p lot of 

i 13 ; pnone CalIS. Just so ou unaerstand tnat. 

114: 

[ 15: issue, 

Did ou calran body else about this 

first in t it 3 

A 

e morning 

Yes. One more person, our general 

! i7”; counsel. Barry Schwartz. 

f13’ 

rlsjthat? 

Q What did you relate to him about 

1:s: A He is our wunsel12:: 0 

[zzladvice. 

I dont ’ want you to go into legal 

eneral counsel. I 

- 

Page 30 

1: :should answer that question. I am hap 

I brought him up to date to te P I

y to do it. 

13: 

!: .him - he, too, dtd not know that I had met with 

[ 5: Monica Lewinsky and did not know that Revlon had 

I 6 1 offered her an opportun. 

.Y‘ So I told him o vthe current status 

; 3 i and we were to meet later that momrng with Mr. 

[ 9~ Gittis and with Mr. Stillman. 

llil Q And who is Mr. Stillman? 

11:: A Charles A. Stillman is our outside 

t 12 I counsel. 

r13: Q And he is also representing you this 

I 14 lmoming, correct? 

115; A Correct. 

116: Q So thats ’ the same Mr. Stillman that 

[ 17 : you identified at the beginning of this 

[ 13 : deposition? 

115: A Yes. 

[zc; Q Apin. I-understand the privilege 

r3:land I dont ’ want 0 aet into that. but did vou 

i33 i have a meeting - y&r just described a meeting 

I 3 3: that you agreed to have later on in the morning 

13 4 : wdh several lawyers. 

125: Did you have that meeting’ 

acaarr -___ ~~ . _-_ _~ 

Page 25 to Page 30 
Page 31 

[I: 

I:: A Yes. 

0 

i: 1 take anv action? 

As a result of that meeting, did you 

isj ’ A Well at that 

[ 6 1 anythrng we did privileged, iif 

int I would consider 

cause I did nothrng. 

[ 7 1 It was m the hands of our attome 

[81 Q Did MacAndrews c Forbes, to your 

I 91 knwae. take anv action - well. lets ’ out it 

[iojthisway: * 

. 

Did MacAndrews 8 Forbes send a 

1 :i i letter to Monica Lewinsky or ask Revlon to send a 

I 13 I letter to Monica Lewinskv with reoatd to her 

i14jempioyment offer? . 

A I subsequently learned that Revlon 

/:z;sent a Letter to Ms. Lewinsky through her 

c 17 I attorney. 

I181 Q 

I191 A 

What did that letter say? 

I dont ’ have that letter. 

Q Do you know what the substance of 

[:yithat letter was in general? 

[22] A I ‘ havent ’ seen it, Tom. 

Q 

j::iunderstandin 

As far as that letter, was it your 

that the letter was in essence 

I I 5 J notifyrng Ms. e ewrnsky that the offer had been 

1297 

Richard Halperin. 4/23/98 XMAX(M1 

Page 34 

[ 3 ldoing it in essenc& for two reasons, to give her 

[ 3 I advice and to also interview her and consider her 

[ 4 J as a possible candidate at either MacAndrews or 

I 5 1 Revlon or one of your companies; IS that correct? 

161 A Yes. 

Q You did that based upon the call 

ii i that you got from Vernon Jordan? 

[91 -A Yes. 

Q 

!:iiVemon Jordan you considered hat o be a 

And the call that pu got from 

[ 12 1 recommendation of Monrca Lewrnsky. correct? 

1131 A Absolutely. 

1141 Q 

rlslthat right? 

She was an entry level employee; is 

[I61 A Yes. 

[I71 Cl How many entry level employees have 

rlelyou interviewed in the last year? 

1191 A Well. I interview secretaries that 

izojwould work at the holding company any secretary 

rzllthat would go into the chairmans ’ office or any of 

rzz]our senior executives I would meet, and in terms 

[z3]0f ent level positions, its ’ not on throu h 

[zs~the ho ?I. ng company that I would 

rzslpeople. 

lZe mee?ing 

(11 

Page 32 

tz J retracted? 

I31 A Yes. 

Q And thats ’ what you had told us when 

fziwe tajked last time, right? 

[6: A Yes. - 

Q Your understanding now is still 

Ii ~conststent with that? 

191 A Yes. 

Q Is Vernon Jordan on the board of 

:: jdirectors of Revlon Mad\ndrews 8 Forbes, or both? 

121 A Revion. 

13; Q Has he ever been on the board of 

14 1 MacAndrews? 

15; A I dont ’ know that MacAndrews had 

16~outMe directors. 

17: I believe he was on the board of 

13 !Revlon. Incorporated and Revlon Group, 

19 1 Incomrated, which is a holding company that 

20 1 prevrously held Revlon, Inc. 

-2, ] I dont ’ believe MacAndrews 8 Forbes, 

s? 1 the utbmate parent, had outside directors. 

23: Q So, to your knowledge, the answer is 

3 4 1 no, he was not on any board that was the 

2 5 1 MacAndrews 8 Forbes board? 

Page 33 

II 1 

.-1 

12: A To my recollection. no, but I could 

[ 3 1 certainty check the records. 

[4; Q Thats ’ fine. 

As far as the phone call on the 1 lth 

t z i of December that you had with Vernon Jordan, you 

I 7 I went ahead and described it for us. igj Could 

I 9 1 walk us through I 

ou just, as bestpu can, 

he conversation 

Who called whom? Did you call him 

~:~jordidhecallyou? 

A I had spoken with Vernon the day 

I :: 1 before on an unrelated matter. And then I believe 

: 14 I he called me that day, and it was a short 

: i 5 J conversation. 

And as I previous 

i :7”; certain whether or not I had !l 

stated I am not 

e lette; in front 

113 lof me But it was a short call. he described 

[ I 3 J Monica Lewinsky briefly to me and encouraged me to 

: z a 1 meet wrth her and give her advice and thats ’ what 

i2:jit was 

17, ‘Lb.. And what I said was I would be happv 

:33!to do rt. 

_ 

Q Now, when you met subsequently with 

i z l i Monica Lewinsky, you indicated to us that you were 

Page 35 

Ill 

[Zl 

r31cant ’ tell 

To answer your question exactly, I 

r 4 1 unusual ii 

ou how many of us, but its ’ not 

r me to even meet an entry level person. 

[51 Q You have indicated to us that at the 

[ 6 1 time you interviewed Monica Lewinsk 

Illwas ’ an oyin 

?&ht 

for a secretary, nght. 1 

that there 

(RI ,..> 

-Q 

_ 

I91 

[ 1 o 1 Mr. Halperin? 

What has happened to that opening, 

1111 

r 12 ! my previous secreta 

A MY *=$aay;;~g$;$;geek 

[ 13 Ifrom California and s e called me over the 

r 14 weekend. so that has been filled. She is coming 

ilsjback. 

;:76;for that job! 

1181 

0 

I:Z;interviews? 

1211 4 

Had you interviewed any other people 

Yes. 

And did you participate in those 

Yes. 

You indicated that you called Bill 

if:iGreen. 

Q 

Dii he a pear to know about Monica 

ISzjLewinsky and the P act that she had interviewed at 

Page 36 

[II 

[ 3 I your company? 

(31. -A - I dont ’ recall: 

0 

i : 1 called him. 

Again. tell me the reason why you 

A Because he runs our Washington 

i; i office and I just, this was really a Washington 

r e 1 story. I wanted him to be informed that this was 

[ 9 1 an issue that was 

[ 10 1 the news world, In 3 

oing to directly impact us in 

he news cycle. 

And I wanted him to be informed 

i :: ; not informed b 

and 

r 13 1 involved with d 

a third party that we were ’ 

Q 

Onlca Lewinsky. 

i : l i Vernon Jordan 

Since your December 11 th call with 

have you had any communication with 

r 16 1 Vernon Jordanat ’ all? 

[I71 A No. 

[I81 Q That would indude not only 

[ 19 I telephone calls or conversations, but also written 

[ 20 1 communication? 

(211 A Correct. 

[221 Q And the answer is still no? 

(231 A Correct. 

[241 MR. BINHAK: 

(251 MR. BIENERT: 

Thank you. 

Thats ’ all I 

Page 31 to Page 36 

- 

olcstafl 
1298 

asA Richard Halperin, 4/23/98 

i161 

1171 

llS1 

1191 

l2Ol 

[Zll 

122: 

1231 

[24! 

I25: 

Page 38 

;1: 

ii i STATE 

CERTIFICATE 

0F NEW YORK ) 

D”NT% NEW YORK ) 

I. ANNETTE FORBES, a Certified 

8~~~~~b~~t~~~~~~~~~~nd 

York, do hereby certii that the 

fore oin Deposition of the witness 

RI&A& E. HALPERIN taken at the time 

and place aforasaid, is a true and 

rozst transcnptron of my shorthand 

I further cert. 

T 

that I am 

neither counsel or nor related to any 

party to said action, nor in any wise 

interested in the result or outcome 

il5: 

:23: 

.-. ~ 

:--. ,-_I. 

.-- ,_1*. 

thereof. 

IN WITNESS WHEREOF, I have 

hereunto set my hand this 28th day of 

April, 1998. 

ZMAZITfrl 

Page 39 

I:-” 

r:3i 

[II! 

1151 

[i6; 

1::: 

iI?: 

[:9: 

,?^, 

.--. 

Page 37 to Page 39 

01298 
1299 

OK-301 (Rev. S-19-94) 

- 1 - 

OFFICE OF THE INDEPENDENT COUNSEL 

Date of transcrrpdon 04/08/98 

GEORGE W. HANNIE, 

White House pager number 

n!' 

extension-, personal cellular telephone 

4-r was interviewed at the Law Office of 

SPRIGGS & HOLLINGSWORTH, 1350 I Street, N.W., Washington, D.C. 

20005, telephone number - The attorneys 

representing HANNIE, and present during the interview were 

STEPHEN R. SPIVACK and WILLIAM B. JACOBSON. After Special Agent 

(SA) 4-p and Criminal Investigator (CI) m. 

w identified themselves and explained the nature of the 

interview, HANNIE provided the following information: 

HANNIE holds a High School diploma from North Port, 

Alabama having graduated in 1965. 

HANNIE began his White House employment as a Butler, in 

July of 1966, and he was promoted to Maitre d' hotel in January 

of 1998. 

HANNIE's duties as a Butler included serving food and 

beverages to the First Family and to their guests. HANNIE's 

typical work day (as a Butler) started at 6 a.m., when he brought 

the daily newspaper upstairs to President Clinton (hereinafter 

referred to as CLINTON) and prepared the morning coffee in the 

kitchen. Normally, there were two Butlers on duty, for each 

eight hour shift, with one Butler starting at 6 a.m. and the 

second Butler starting at 7 a.m. -After serving the meal to the ' 

First Family, HANNIE remains in the area to clean up. 

As a routine, CLINTON takes his breakfast or coffee in 

the kitchen.- CLINTON has only engaged HANNIE in conversations 

about sports or weather; CLINTON never engaged HANNIE in any 

conversations about MONICA LEWINSKY, nor has HANNIE ever 

overheard the First Family mention LEWINSKY. 

Investigation on 04/06/98 at Washington, D.C. File# 29D-LR-35063 

Date dictated 04/08/98 
1300 

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

29D-LR-35063 

Continuation of OIC-302 of GEORGE W. HANNIE ,On 04/06/98 . Page 2 

In preparation for serving the CLINTONs, HANME had the 

opportunity, during the transition period in December 1992 and 

January 1993, to speak with CLINTON's mother, Secret Service 

Agents (no specific identities), ANN MCCOY (recently retired from 

White House), an Arkansas State Trooper named MARK Last Name 

Unknown (LNU), and CAROLYN HUBER (former White House employee), 

about what foods CLINTON prefers. HANNIE mentioned these 

individuals because he believed they were the most knowledgeable 

about CLINTON's food preferences. 

HANNIE said whenever it appeared as though CLINTON was 

having a personal or private conversation on the telephone or in 

person, HANNIE departed the area to return a few minutes later, 

but HANNIE was never excused from the room by CLINTON. HANNIE 

never had any reason to believe that any of the CLINTON's 

personal conversations were with LEWINSKY. 

Ninety-eight percent of the time, CLINTON takes his 

lunch in the Oval Office which is provided for by the "Navy Mess" 

which, according to HANNIE, operates independently from the White 

House Residence Staff. HANNIE did not know who would have 

additional information on the "Navy Mess," or their routine of 

services to CLINTON in the Oval Office. HILLARY CLINTON normally 

takes her lunch within the Residence. 

HANNIE's position as a Maitre d' hotel is an 

administrative one that requires HANNIE to coordinate the hiring 

of additional butlers and kitchen staff for White House 

functions. In addition, HANNIE also signs vouchers and assigns : 

work duties to other staff members. His work hours are from 

7:00 a.m. to 3:00 p.m., five days a week. 

HANNIE recalled one occasion in which CLINTON held a 

meeting in the Map Room (ground floor of the Residence), while 

HANNIE stood by outside in the hall. HANNIE noticed that 

LEWINSKY walked down that hallway approximately 10 to 15 times, 

within a two-hour period. LEWINSKY carried documents in her hand 

and commented to HANNIE, "Paper work, Paper work!" in response to 

HANNIE's comment about her appearing very busy. HANNIE believed 

that this occurred at a point in time when CLINTON held 

l'Coffees,t' prior to his 1996 re-election. When that incident 
1301 

OK-302a fR:\ 8-19-94) 

29D-LR-35063 

Continuation of OK-302 of GEORGE W. HANNIE .On 04/06/98 ,Page 3 

occurred, HANNIE was accompanied by another butler named JAMES 

SELMON. 

In December of 1997, at a White House Christmas party, 

LEWINSKY asked HANNIE if he would arrange a tour for her of the 

Residence (second floor, private quarters). LEWINSKY told HAN-NIE 

she was leaving the White House because she had secured 

employment in New York. LEWINSKY did not discuss her New York 

employment with HANNIE and HANNIE advised LEWINSKY to see the 

Chief Usher, GARY WALTERS, to arrange a tour. 

At some time in early-January of 1998, HANNIE ,was 

leaving the White House at the conclusion of his shift when he 

saw LEWINSKY at the South East Gate (Al) and she was visibly 

upset. LEWINSKY said to HANNIE, "They won't let me in," and then 

asked HANNIE to give an envelope (held by LEWINSKY) to the "big 

man." HANNIE, wanting to be clear on who LEWINSKY was referring 

to, asked LEWINSKY who she meant. LEWINSKY replied, "The 

President." HANNIE described the envelope as a plain white, 

letter-sized envelope. HANNIE instructed LEWINSKY to deliver the 

envelope to the Usher's Office for delivery. 

HANNIE has never heard rumors or gossip concerning an 

alleged affair between CLINTON and LEWINSKY, nor does HANNIE have 

knowledge of LEWINSKY's departure from her White House employment 

to the Pentagon. HANNIE has never heard any information about 

LEWINSKY's job performance while she was employed at the White 

House. 

FANNIE advised that no one has attempted to influence 

his recollection of the above events or interfere with this 

interview. 
1302 

01302 
13b3 

- 

OK-302 (Rev. 819-94) . 

OFFICEOFTEIEJNDl?PENDENTCOUNSEL 

Date of lmsaipioa 06/02/98 

OLIVER RILEY HEMSLEY, Officer, United States Secret 

Service, (USSS) Uniformed Division (UD), date of birth, I, 

m, SSANl_ was interviewed at the Office of the 

Independent Counsel (OIC), 1001 Pennsylvania Avenue, NW, 

Washington, DC, 20004. Present for the interview were Associate 

Independent Counsels (AIC) MICHAEL TRAVERS and MARY ANNB WIRTH; 

Department of Justice (DOJ) attorneys, JANIS KESTENBAUM and ANNB 

WEISMANN. HEMSLEY was interviewed under the terms of an 

agreement reached between the OIC and the DOJ. After being 

apprised of the official and personal identities of the 

interviewers and the nature of the interview, HEMSLEY provided 

the following information: 

HEMSLEY entered on duty with the USSS on December 17, 

1985 and was initially assigned to various posts at the White 

House. In 1993, HEMSLEY was assigned to the w post in the 

basement of the West Wing. This assignment continued until 

August 1996, when he became the White House Branch Fitness 

Coordinator and Training Officer/Certification Officer. HEMSLEY 

said he continues to stand duty at various posts, as needed, but 

he is not permanently assigned to any post. 

HEMSLEY advised that he does not know the first time he 

saw MONICA LEWINSKY but believes it was during the time she was 

an intern at the White House. He remembers LEWINSKY seemed to be 

"starstruck" and "not like most interns." She came to the West 

Wing more often than other interns and she wore tight fitting 

clothing apparently to "show off her body." HEMSLEY stated that 

each time LEWINSKY came to the West Wing through the q post, 

even though she was wearing a pass, he would detain her until 

someone came to escort her. 

HEMSLEY stated that he has heard at some unrecalled 

time or times, rumors about the President and LEWINSKY having an 

affair and at some point the rumor was "common knowledge." 

HEMSLEY also heard the rumor that LEWINSKY and the President were 

caught alone in the White House Theater, by LEWINSKY's supervisor 

named JOLLEY or an unidentified military aide. This apparently 

resulted in LEWINSKY being transferred to the Pentagon. 

HEMSLEY also heard from other UD personnel that White 

lnvestigatioo on 05/29/98 at Washington, D. C. Fitcl 29D-OIC-LR-35063 

Daedicmai ()6/02/98 
1304 

- 

OIC-3u2a (Rev. 8-19-94) 

29D-OIC-LR-35063 

cblsimation of or.-302 of OLIVER RILEY HEMSLEY .on 05/29/98 . Page 2 

House Steward NELVIS had to clean up "the study" after LEWINSKY 

and the President had been there "doing something." HEMSLEY said 

that to the best of his knowledge, LBWINSKY and NELVIS did not 

have any kind of social or business association. 

HEMSLEY heard the rumor that the President and0 

_ had an affair during the 1996 election campaign. HEMSLEY 

advised that for a period of time he was acting as a personal 

trainer for sand one day in the gym she was clearly upset 

by the fact that someone had written a story about an affair 

between she and the President in the STAR magazine. -de 

the comment that she couldn't believe people would lie about 

things like that. She denied that any of the story was true. 

HBMSLEY said he heard about the Northwest Gate incident 

involving LEWINSKY, ELEANOR MONDALE and the President, primarily 

from Officer CHINERY. HEMSLEY said his recollection is that 

Officer HALL said something to someone else, which greatly upset 

LEWINSKY. HEMSLEY thought that LEWINSKY may have overheard HALL 

say that LEWINSKY, who was trying to get in to see the President, 

would have to "take a number." HBMSLEY remembers that CHINERY 

said he spoke to Sergeant WILLIAMS and BETTY CURRIE about the 

incident and CHINERY informed HBMSLEY what he learned from his 

inquiry. 

invoked) 

(Protective Function Privilege and Executive Privilege 

HEMSLEY said he remembers two occasions when he saw 

LEWINSKY somewhere other than the White House. The first 

occasion was when he attended a function at the Washington Hilton 

on Connecticut Avenue. HEMSLEY was in charge of the Magnetometer 

Team for this event and noticed that LBWINSKY was present. The 

President was also supposed to make an appearance and HEMSLEY 

became concerned that she might try to get too close to the 

President. HEMSLEY, being aware of the rumors of the 

relationship between the President and LBWINSKY, decided that the 

uniformed and plainclothes Secret Service details should be 

notified. HEMSLEY told the supenrisors of each unit about her 

presence and, as HEMSLEY remembers, it was necessary to tell them 

the reasons for his concerns since they apparently had not heard 

the rumors. HBMSLEY could not recall the name of these 

supervisors or the date of the event but did remember that it was 

after LEWINSKY had left the White House. 

The second occasion was at an unrecalled outside event 

at the Pentagon (possibly a military anniversary) where the 

President was to make an appearance. HEMSLEY was in charge of 

the Magnetometer Team for this event and noticed that LEWINSm",< 
1305 

olc-UIzt (Rev. &1944) 

29D-OIC-LR-35063 

fi2miaation of oKxw2 of OLIVSR RILEY HEMSLEY .on 05/29/98 .Pqe 1- 

was present. HEMSLEY did not alert Secret Service Special Agents 

or other security officers, because he did not think LEWINSKY 

would be able to get close to the President and that she was not 

a threat to the President. 

EEMSLEY stated that he observed a person possibly 

related to the PAULA JONES case, 

the _ and * post,' 

while working as a fill-in at 

occasion. 

during the last year on more than one 

(Protective Punction Privilege.invoked as to all these 

obsenrations) 
1306 

01306 
1307 

Brian Henderson, 3/l 3198 

OIC Deposition 

Page 2 to Page 

CONDENSED TRANSCR,lPT AND CONCORDANCE 

PREPARED BY: 

OFFICE OF THE INDEPENDENT COUNSEL 

1001 Pennsylvania Avenue, N.W. 

Suite 490-North 

Washington, DC 20004 

Phone: 202-5 14-8688 

FAX: 202-5 14-8802 
1308 

BSA Brian Henderson, 3/13/98 XhlAX(1) 

Page 2 Page 5 

-. OFFICE OF THE INDEPENDENT CGGNSEL :::todayy 

:~‘_____-__---_---__--____-x ,_: 

.-. A Yes, sir. 

;3: Q Do you understand that if you do not tell the 

:4! DE::S:TION OF Friday, March 13. 19yt 1 ij truth. that if you lie or mislead or say, for example, “I 

.-j i 5 !don’t recall”, when in fact you do recall somethlng. that you 

6‘ PFI.?: M. HENDE?.SON : Washington, D. C. 

:_; 

16) may be prosecuted for that’ 

[ii A Yes, sir. 

i9j_____-________-__-_______x Q Do 

iilthe questions that Y 

ou understand also that if an answer to one of 

iy,mpo5::;on of ask you may incrimtnate you in some way, 

!:3! BRIAN M. HENDERSON [ 10 j that you may assert your Fifth Amendment privilege and not 

:;;]Defore rhe Indepenoent Counsel, held I" the Conference 3~3~ 11 I : answer that question? Do you understand that? 

i:2]of tte 3fflce of rhe Independent Counsel, 1n SulLe 4CZ-Szr:r., [:': A Yes, sir. 

!:3!100: ?ennsylvanla Avenue, N. W., Washlnqton, I?. C. :C3.‘;, ;13j Q Why don’t we go ri 

~:q,begl:.zlnq at 117:s; a.zn., when were preser?:: :: 4 ] you tell us about your professlona 

'15; For the :ndependent Counse;: A Okay. Currently I am a 

::6! iizjoff~cer with the Secret Service. 

. 7: 

131 

ROBERT 2. BITTMAN, ESQUIRE ;17; Q What is your rank? 

Deputy Independent Counsel 1131 A Officer. 

[lO! ROD‘ER A. HEATON, ESQUIRE (191 Q 

A 

How long have you been a uniformed officer? 

[L'O] Ass~clate Independent Counsel 1201 For seven years, sir. 

:~:]Court seporter: Elizabeth A. E2.s:xz.r. Q What did you do before you joined the Secret 

‘“I SC- I5 i i Service? 

1731 A I worked for a company known as Federal Express 

[24] IZ:{Corporation. 

:r!si 1251 Q How long had you worked for Federal Express? 

___~_ ._~~ -

Page 3 

!I1 PROCEEDINGS 

12 1 WHEREmN 

L31 BRIAN M. HENDERSON 

Page 6 

A 

Q 

Approximately five years, sir. 

What did you do for Federal Express? 

A I was a dnver. 

Q 

[ 4 1 having been called for examination by the Office of the 

1;; 

: 5 1 Independent Counsel, and having been first duly sworn by the 

[ 5 1 the Secret 

Do $0~ remember exactly the date that you joined 

Service. 

[61 A 

[ 6 1 notary, was examined and testified as follows: 

EXAMINATION BY COUNSEL FOR THE INDEPENDENT COUN&.Se~ice? 

Q 

January the 7th of 1991. 

What has your training consisted of at the Secret 

:i! 

I91 BY MR. BITTMAN: 

19: Q Good morning. Officer Henderson. 

G3j A Good momin-. 

:::i Q My name is F9 obert Bittman. I am a Deputy 

: :Z 1 Independent Counsel in the Office of Independent Counsel 

: 13~ Kenneth Starr, and ou are here a 

; 1 I 1 testimony in the ma !t er of Monica e 

pearing today to give 

ewlnsky. 

3! We are proceeding today outside the 

: i 5 1 Iwant to let 

grand jury, but 

Y 

ou know that we intend to make this transcnpt 

:T 1 available to he grand ‘ury. So it would be covered under 

. . -9 ! the Federal Rules of c!. nmlnal Procedure. Do you understand 

i”! A At this point I need to speak to my attorneys. 

:?o! 0 I will wlthdraw the question. You do not have to 

[ 1 I 1 answer that question. 

Can you tell us where you have been assigned while 

[ :; j you’ve been at the Secret Service? 

A 

/ :: i was in training. 

Yes, sir. From January 7th of ‘91 up until S-91 I 

From 5-91 to approximately March or April 

[ 16 1 of ‘96 I was assigned to the White House Branch. From March 

[IT! or April of ‘96 to approximately February of ‘97, I was 

!:31 assi ned to the Forei 

[ 19; And ?r om February o P 

n Missions Branch in Washington, D. C. 

97, 

L 2 0 ] Center. 

I’m assigned to the Rowley Training 

(2:: Q So, your first assignment was at the White House 

;:z;Branch? IS that n 

w? 

ht? 

I ness nodded indicating an affirmative 

::slthat? 

;:01 A Yes. 

:21! Q Do you understand that you are here today as a 

: ~2 ! witness and that you have certain rights and obligations as a 

: 23 1 witness? You have a right to have attorneys present outside 

r: 4 1 of this room. Do vou understand that? 

:I?51 A Ye& sir 

Page 4 

Q And I understand that you do have a number of 

ii ; attorneys outside from the Department of Justice and also 

: 3 1 from the Secret Service available to you outside this room. 

4 1 Is that right? 

is1 A Yes, sir. 

[El Q Do you understand that at any time I ask you a 

[ 7 Iquestion and you wish to consult with the attorneys, 

P 

lease 

; 3 1 let me know and we will take a break and you can ta k to the 

I 9 1 attorneys. :ioi _ A Yes, sir. 

Q I know you have been instructed that at various 

iii; times vou mav have to do that. and I encourage YOU to do 

ifjjthat. okay? e 

_ _ 

:x4: A (Wiiness nodded indicating an affirmative 

: 15 1 response.) 

Q 

i 1: 1 to tell the truth. 

You also have certain obligations. One of those is 

Do you understand that? 

:131 A Yes, sir. 

Q Have you been instructed by 

i: zi the truth? That is one of the agreements tha Y 

our attorneys to tell 

we have wtih 

; 2: 1 them. that you are to tell us the complete truth as far as 

::z;the questions that they will allow you to answer. Do you 

: 2 3 1 understand that? 

1-41 A Yes, sir. 

::51 Q Is that your intention, to tell the truth here 

olcstarr 

(231 A 

~24jresponse.) 

[?5j Q From 5-91 through when in 1996? 

Ii j month of $3. 

!3! 

Approximately March or April. I’m not sure which 

What did you do at the White House Branch? 

A When I first arrived at the White House Branzh I 

ad three different assignments there, is 

Page 7 

ev needed me to work in 

Page 2 to Page 7 
1309 

Brian Henderson. 3113198 XMAX12) 

Page 8 

Q 

_: 

When did you get your permanent post? 

-. 

:,‘93 and I fifhwd up ap roxrmately August of 

I worked my permanent post ap roxrmately July of 

8 

l 5. I’m 

: :sorry. March or Apnl o 96, rather. 

:. - Q Until you left? 

;‘ 

-_ A Exactly 

Q What does an unassigned officer do, or what did you 

s ;do as an unasstoned officer? ;: A & an unassigned officer. I was assigned foot 

; jbeats. I was assgned the various internal and external 

: 1 posts. It was my ob to make sure to monitor the ingress and 

: !egess of passhot& rs And, again, basically to be plug 

?I 

ed 

3 !w erever was needed, whatever shift I was needed, w atever 

4 idetail I was needed. 

:’ _. Q You were sort of a fill-in guy? 

-5, A Yes. srr. 

._. Q WlMe ou were an unassigned officer, that is, from 

.2 i May of ‘91 through Ju 

ilWina? 

L of ‘93, did you ever work in the West 

--> ., 

.x1 A Yes. sir. 

~. 1 .--> Q Approximately how many times? .-^l A I couldn’t recall exactly. Approximately, I’d say, 

:?ithree to five times. something like that. 

0 Tell me what you did when you were working at the 

: i i 1 WAVES Center. 

Page 9 

1 A Basically, it was my res 

P 

onsibility to assist 

:I j civilian personnel in the clearance of a I staff members, any 

:2!visitors to the White House Branch, do an 

: a 1 any criminal checks, initial checks before r 

background checks, 

: 3 1 forwarded to another level. 

hey were 

:i1 0 Once again, was this sort of a fill-in capaci 

: - t that when somebod 

: 3 i you would~ll in for &em? 

was out sick or on vacation or somet X! rng, 

Basically. I did receive training, but, yes, I was 

i 11 a fill-in in that ca aaty. 

.., __I Q fell me what vour oermanent oosts were between Julv 

Page 10 

A Well. after I was wrmanentlv assioned at one oost 

jr? iAugust of ‘95 until you left you worked 

-:: 1 relief of6ceAfl 

is the East Wing 

__I --I I’m so Repeat the uestion. lease sir? 

.131 Q When 7 

A 

rdyouworkas 9 he East 

Z4! I worked from Au ust of ‘95 u 

Lng relief officer? 

.: 5 1 March or April of ‘96 as a relief o 7f. icer In the /! 

until approximately 

ast Wing. 

Page 8 to Page 13 OlCStarr 

Page 11 

. 

i 5 ; officer. 

Q 

did 

Even though you were called the East Wing relref 

you ever serve in the West Wrnq7 

3: A Yes, sir. 

4: Q Approximately how many times dunn August ‘95 

5 1 until you left in early 1996 did you serve in the West 

i: A 

brnp? 

Agarn. that’s somewhere around three to rve hmes. 

-1 I don’t recall exactly. It wasn’t ve many. 

Can you describe x tose occasions to me? Were you 

ain filling in for somebody? Was it always the 

Page 12 

[ I I if he needed someone on the other side, and if we had enough 

r2lman 

cP” 

wer to cover the other wing, then I would be plugged as 

[3jnee ed. 

141 Q 

[s] Win 

You said you had no formal training to be a West 

[ 6 1 Eas P 

officer. Do they receive different training than an 

Wing officer? 

A They receive certain training that again that’s 

Ii 1 different from the - yeah I mean because of where you are 

[ 9 I at. Wherever you are assigned at the White House complex, 

:o 1 you have to have the training. 

ii] 0 Is it#st sort of a familiarity with, the area 

12!though, or is it a d erent 

13 1 that. 

- maybefly: shouldn t get Into 

I don’t know how necessa 

?41 So, between Au ust o ‘95 and through early ‘96. 

15 ; you served approximately 9 hree r7 to five times in a security 

16 1 apaclty in the West Wing. 

171 A Yes, sir. 

Is that right? 

181 Q Have you actually checked to see how many times you 

.19 1 did serve over there? 

1201 A No, I have not, sir. 

[ 2 s 1 question is, when 

~___ 

Page 13 

[I !was the President over there while you were serving. 

‘!21 These three to five times thatJou served In the 

[ 31 West Wing were you alwa s in uniform 

Cd! A 

Q 

To rn$ recoiection, I was, sir. 

Are t ere some times that you serve in the White 

i 2 i House when you are not in uniform? 

171 A Yes. sir. 

isj 

!91 i ~h$&%% t%%ru East Wing, 

[ I o 1 Iwould wear civilian attire. 

ill: Q So, even thou h 

[12lyou are not atwa s in uniform. 37 

ou are in the Uniformed Division, 

s that right? 

[I31 A Txat’s correct sir. 

1141 0 So, when I asked, when you served in the West Wing 

[~slwhether you were in a uniform, are you saying a suit? Or 

r1slwhat is your uniform? 

.i7j _ A M uniform? 

Q V&at was your uniform as a uniformed oft&r in the 

ii”, 1 Secret Service between August ‘95 and early 1996? 

!20! A Okay. From Au ust of ‘95 until March or April of 

[21~‘96, I did wear the black and o d uniform. 

0 Black and goli !niform? 

t your permanent post, 
1310 

BSA Brian Henderson. 3/13/96 XMAXl31 

Page 14 Page 17 

A Most of the time. no. srr A - ^. Q 

A 

When would you wear rt? 

Okay Actually, there’s two. That would actually 

-. be while the Presraent is in the office, this is - well I 

3. Generally, it was a civilran attire post, which -i!krnd of consider these two the same post, but it’s - 

; :consrsted of a blue blazer, 

5: you wanted to include with 9 

ray slacks. and any accessories 1. Q You have to identify it on the record Are you 

he uniform or the suit and tie. 

The three to five times you served in the West Wing 

-5:talking about walkway #l? 

_. Q 

:.between Au 

._: A That’s correct, sir. 

3: and gold unr 9 

ust ‘95 and early 1996, did you wear your black Q And walkway #2. that is sort of the same oost? 

orm? 

.3: A To my recollection, yes. as far as I can recall and 

: : 3 : remember. 

. . . Q 

if_:you served in the 

Doxpu remember which corridors. or where exactly 

:;3: A 

est Wrng on those three to five hmes? 

Okay. At this point I would need to talk to the A Walkwav #l sir 

; ; 4 : attorneys. 

;15: Q Oka 

;:c:questions to ask: x 

Lets take a break. So. you have two 

ow many times was the President there, 

; ~7: and which times was the President there when you served In 

: 19: the West Wing between August ‘95 and when you lefl in earty 

::‘j - 

::?I 

.._g: A0 Yes* sir. . 

119 1’96; and then exactly where did you serve. A I’m sorrv. Go ahead.. 

;:o: A Okay. 

IZ!‘ Q All right. We will take a break. The time is 

i~jll:OB. 

i??, NVhereuoon. the deposition was recessed from 11:08 a.m. 

~7~juntilll:lSa.m. ’ ’ 

[‘5; MR. B ITTMAN: We are back on the record, and it is 

Page 15 

[l>t-iow 11:15. 

I - : BY MR. BIT-l-MAN: L-. 

Q The first question was, when 

I: i the West Wing, between August of 1995 an dy 

ou were serving in 

when you left in 

I 5 1 early 1996, how many times was the President there? 

[6: A To my recollection. I’d say about three times. 

:71 Q Then my question was, where exactly did you serve. 

i EC: On the three to five times that you served in the West Wing, 

19 1 where did ou serve? 

1 

jlE;Oval- I’m sorrv. 

Okay. I recall serving at the vts outside the 

as the question when he as there? 

:. _: 

.-D ‘was marked for identification.) 

,.y. 

.-,> BY MR. BITTMAN: 

0 Let me show you an exhibit that is marked 

i i z j Deposition Exhibit Henderson #1 

: :o i is a map of the West Wing. 

with the date 3-l 3-98. That 

: ; 1 l ,,as k~nA.witinn nn it Do you recognize it? It already 

,“_)T 

.__ 

t IIOII”“II.Ill “II I,. 

A .~~. 

i::iserved? 

Q 

?It’s a little sketchy, but, yes, sir. 

Can you identify on the map the - post where 

‘?<‘ 

.--. A Okay. That would be here. 

YOU 

Page 16 

. 7 ii. Q Is that walkway #l? 

[‘; A 

Q 

Right. That would be this area right here. 

!3: So, it’s actually walkway #2? 

[J! A Yes, sir. 

IZ, 

; i; don't 

Q 

vou? 

Can you handwrite on there? You have a blue pen. 

Q At least three times. 

ji:;the Oval Office? 

That is, directly outside 

!16j A Yes, sir, that I recall. 

!17: Q Of those three times that you served in the- post 

; 19 : between August ‘95 and when 

7y 

ou 

; I 9 1 times was the President there. 

left in earty ‘96. how many 

;20j A I would say at least once, sir. 

[Z?‘ Q At least once. Would there be any reason for you 

: : 9 ; to serve there if the President were not there? .--. 

:23: A Yes, sir. 

Q You mentioned that you remember serving in at least 

ii:.one other location. Where is that location? 

Page ia 

A Yes, sir. 

Q Where is the other location where vou served in the 

::?]I 

::3j $ No, sir, I do not remember. 

:191 .^“. A 

:231- 

:24; ; Would you repeat that auestion for me? 

._=. _a! t 

Page 19 

:: 1 include down and checking hallway #t4? 

‘71 _-. 

wadfting 

;3! Q 

No, srr. I would say no. 

! 4 1 Jocelyn Jolley. 

Okay. Let me turn now to a woman by the name of 

: 5 1 Jolley? 

Do you know a woman by the name of Jocelyn 

:6i A Yes, sir. 

r-1 0 

:9i A 

How do you know her? 

I worked in the East Wing, and during my tenure 

j 3 1 there she worked in the East Wing as a staff member for the 

: : 3 1 Administration. 

..> ..A1 Q 

A 

Describe your relationshi 

.I,] .-- Amicable, friendly, as we P I as professional. 

with her, please. 

“33 .- Q 

::A] A 

How often would you speak to Ms. Jolley? 

Normal 

Q 

when I saw her, hello, how are you. 

I :z i for weekends? 

Would t 2; at be pretty much on a daity basis, except 

::?I A That would be pretty fair to say, sir. 

:1?! Q 

; : 3; be 

Would it be fair to say that this 

3 

an when you had your permanent post t& 

ationship 

a or was it 

::olbe ore that? 

97, .-A> A 

‘7-j Q 

I would say permanent post, sir. 

i_;lapproximately? 

So, that would have started in July of ‘93, 

‘24) A Yes, sir. 

:25; Q Do you know a woman by the name of Monica Lewin 

Page 14 to Page 19 
1311 

BSA 

Page 20 

Brian Henderson, 3113198 

Page 23 

XMAX(4) 

(1’ 

._: 

A Yes. sir. 

.-, 0 

A 

How do you know Ms. Lewinsky? 

[3i A 

:; !offrcer there and 9, 

ain. I was assigned to the East Wng as an 

[51well. 

er offtce again was in the East Wrng as 

161 Q Were you friends with Ms. Lewinsky? 

(7’ A Professional. amicable. 

i?j 0 Would you speak to Ms. Lewinsky on a regular basis? 

(9: A No, sir. 

[lo: Q Do ou remember when Ms. Lewinsky began her 

[ 111 employment in thebhite House? 

Cl?1 A No, sir. 

0 Do you know that Ms. Lewinsky went to work in the 

i :~iOffce of Le islative Affairs in the correspondence unit 

: ,--_ 13 1 where Ms. 3 ollev worked? 

116) A Yes. sir. 

Q How far apart were Ms. Jolley’s office and Ms. 

1 :I: i Lewinsky’s office? 

A Okay. If my memory serves me correct, I believe 

ikiithey were an office a 

[:I] I thmk they had an R 

art, akhough I do not really recall. 

o 

12: 1 Iremember. 

ice adjacent to each other, so far as 

0 You said you s 

Ii:idaily basis. Did you speak to 

oke to Ms. Jolley re 

[ ~5 ! basrs? 

bs. Lewinsky on aLo%?%$yon a 

it!left. I wasdone., 

Did you talk to her before she was actually 

t;;term~nated~abo~$~thes oossrbrlrty that she may be termtnated? 

id! 

I 5 . : Q You drr not? 

(6: A No. 

[I21 A I don’t recall. 

1171 Q 

i ii; happened? 

You don’t recall that. So. that could have 

il5j ” A It could have happened 

[I61 Q If she sard that, that could have happened? 

(17; A Yes, sir. 

Q And that she then asked you why she should watch 

::“9{ her back? Is that ringrng a bell at all? 

[201 A Yes, sir.- 

(211 Q Tell us what 

r 

ou remember. 

r22i A 

i23i 

At this point. need to talk to mv attomevs 

Q Okay. 

I%:;until 

(Whereupon. the deposition was recessed from 1130 a.m 

12:02 p.m.) 

_ 

Page 21 

[:I A Only if she had need to ask me a question 

[z I basically. 

Q You were more friendly with Ms. Jolley, or better 

I: i friends with Ms. Jolley than you were with Ms. Lewinsky. Is 

[ 5 1 that fair tozay? 

[61 I would say more sociable, es, sir. 

Did you ever socialize with ks. Jolley outside 

;;jwork? 

Q 

[91 A No, sir. 

[?Ol Q Did 

r 

ou ever talk to her outside work? 

[I?] A Not hat I recall, sir. 

i i; i was strict1 

Q So whatever relationshi you had with Ms. Jolley 

R at the White House. 

;i4;Isthatfarr. .X 

from your work and her wo 

1151 A That’s fair to sa sir. 

[:6: Q Would that bet b, e same with Ms. Lewinsky? That is, 

; IT! did you evr cor~~~~~s. Lewrnsky outsrde the White House? 

:13: 

Q Do' you remember when Ms. Jolley was terminated from 

I ii1 her employment at the White House? It was in early 1996. 

Page 24 

[II (Mr. Heaton not present 

[21 upon reconvening.) 

[31 BY MR. BlTTMAN: 

141 Q Officer Henderson, do you remember the question? 

1s IThis was about Ms. Joke 

[ 6 1 Jolley before she left. bs r 

and your conversations with Ms. 

ore she was terminated from the 

~7 1 White House. 

[El A I do now recall that conversation with her. And 

[ 9 1 the reason wh 

[ 10 Iwould be due tv o the fact that there was a lot of tra 

I wou!d tell her something like that 

ffp 

rimarily 

IC from 

back and forth to the West Wrn 

e was on a 

(211 A Yes, sir. 

Q What is your understandin as to why Ms. Jolley was 

tgf i terminated from her emplo nt at the &ite House. 

[:4: A At this porn tyme , Ineed to speak to my attorney. sir. 

1251 Q Okay. 

il‘ 

Page 22 

(Whereupon, the deposition was recessed frDIn 2 5 j 

i2ja.m. until 11:49 a.m. 

[3i BY MR. B l+r MAN: 

[4! Q Officer Henderson, I remind you that you are still 

r 5 1 under oath. It is now 11:49. 

The question I asked was, what is 

i: i understanding as 

our 

i 3 j the White AHouse? 

to why Jocelyn Jolley was ty ermrnated from 

[ :,‘; House. 

I don’t know why she was terminated from the White 

No one of an official function or su 

[ 111 position, or anyone in connection with her, Ks a%??me why 

[ 12 1 she was terminated. So, I don’t know why. 

1131 BY MR. HEATON: 

r14i Q So, you don’t have any understanding at all as to 

i 15 j why she was terminated? 

A I don’t know why. Anything beyond that would be 

i it 1 speculatin I don’t know why. 

Cl81 

Q 

8Y MR. YTTMAN: 

Did ou talk to Ms. Jolley about why she thought 

i:zishe was terminate ? 

[21! A I have not. 

[?:I Q You’ve never talked to Ms. Jolley as to why you 

(2 3 1 thought she was terminated. or she thought she was 

[I 4 ! termmated: 

[Z51 I have not. When she was terminated, I had already 

~~~~~ 

Page 20 to Page 25 

Page 25 

[ 1 lwant to sit here and say somethin 

% 

I don’t remember. But, 

[;! 1 again. the observation was the tra 

[ 3 1 forth traffic. 

IC, the going back and 

/: i telling 

Q 

Ms. 

Can you tell me the gist of what you remember 

Jolley when you su to her that she watch 

i 6 1 her back, and then she asked 9 

gested 

he logical question, why. Then 

[ 7 1 what was the gist, not exact words you told her, but the gist 

t 8 I of what YOU responded? You obviously had some intent to QO 

i 9 j to her and tell her to watch her back. _ 

A Right. The gist of it would be the fact that she 

I :i 1 was on a power krck 

[I21 0 She, bein who? 

I :: i was her supervisor, I 

A lmsorr&:8l. s Lewinsky. And being that Ms. Jolley 

Ink she just made supervisor, I’m not 

rlslquite sure, you are looking at an intern who, for some odd 

[ 161 reason, would go back and forth to the West Wing all 

[171throughout the day, and trying to make herself look more than 

118 Iwhat she is,, or maybe she was, if you will, for a lack of 

[ 19 1 better wordrng, kissing up. 

0 What was Ms. Jolley’s reaction, as far as you could 

~~~itell. after you were explaining the gist being that you think 

[ 22 1 Ms. Lewinsky was on a power tri 

[zJ]that there was no reason for her o 

p, ring back and forth, and 

ave that much traffic 

(24 1 back and forth to the West Wing, right? 

[251 A In my opinion, no. I mean, not for an intern. I 

OlCStarr 
1312 

BSA Brian Henderson, 3113198 XMAX(5) 

Page 26 

11 Idon’t mean, you know - 

‘71 X-l 0 Not for an intern? 

[3: A 

Q E$%vme, she wasn’t an intern any more She was 

I : i workmg for Ms. Jolley? 

A That’s where, as far as her being an intern. I know 

1 t i she worked for Ms. Jolley. And I’m not quite sure if she 

(8 1 still had an internship and an intern pass, but - you know, 

rslyou have different passes and it may have been a hard pass 

rioland she was still an intern, which means she had more access. 

i 111 But still. even still, based on what I can recall - and I 

[ 12 ]don’t know all about her, what all she did as far as working 

r 1 ?lwas concerned. but based on mv observations. it was a brt 

i ;; j m;cti ira-EC. 

1151 Q 

i 16 j her reaction? 

After you explained this to Ms. Jolley. what was 

A Hmm. Well obviously concern. And beyond that, 

i :i; that was about it. It was m’ore or less, you know, watch your 

Page 29 

.: 

1; 1 because y& have a lot of traffic’over there. 

It may sound odd but not necessanly I mean, 

;31 that I onl 

I mean ‘being 

j 4 ! from the k 

worked over there - I remember her more 

ast Wing, going back and forth to the West 

orng 

%Jrng. as 

i 5IOppOSed to her berno there. If I saw her. maybe R was for a 

!h]second or so. - 

[-I But I can’t honestty sit here and say that I 

! 8; actually remember seein 

;g:sure she was there. As B ar as me and her at the same 

her In the West Wang. althou 

9 

h I’m 

I 

; i o jdon’t remeQmber. 

tme. 

!11! how is it that ou remember 

; ;;; Lewinsky Tins- 0 t e West Wrng J 

s Lewtnskv would - it would be a lot of travel 

MS 

ii9jemployee. 

[.?01 Q 

rzlljob? 

So, she expressed sort of her own concern for her 

A I wouldn’t say for her job. I mean, 

I;:ifar as her employee was concerned, you know, I cr 

ou know, as 

(24 1 know what was oing on in her head, I mean. 

or-0 really 

I251 0 Aght. 

i : 4 j going back and forth to the West Wing. Many trmes on many 

‘1s !occas~ons she would ask the President’s schedule, 

;~slwhereabouts. And, again, she would appear to me to be on a 

[ i 7 1 power kick. 

On the weekends when no one else was around 

i:iiworking in the East Wing. she would be there. Whether she 

[ zo 1 was working or not, I really don’t know. Constant travel 

iZ1) back and forth. There was a skeleton staff there of White 

[zz 1 House members on the weekends. So, there was some work 

1~3;ahvays to be done. But, again, I mean, I don’t know what her 

[24 1 responsibilities entailed. 

1251 But, in my opinion, on the weekends, her being the 

Page 27 Page 30 

[li A Again, as far as her employee was concerned, that 

12 lwas my concern. Maybe I should have mrnded m business. but, 

[ 3 J you know, again, I see someone who IS orn ba Jandforth 

[ 4 j and, in m 

I 5 I people. 3 

opinion, was not necessarily Ike 

7 2 

by a lot of 

ower struggle. And a lot of what I perceived and 

[ 6 1 speculated to be unnecessary errands. 

Q Did Ms. Jolley seem su rised when you told her 

Iziabout this;nreasonable amount of tra r;p c by Ms. Lewmsky? 

[91 I don’t remember. I don’t remember. 

Q Did you have any other conversations with Ms. 

i 1:; Jolley abo;t Ms. Lewinsky? 

112: Not that I recall. 

Q You don’t recall. Do you remember anything else 

I :: i about the conversation, that is, what you told Ms. Jolley in 

[ 1 j 1 this conversation shortly before she was terminated from the 

1161White HOI.?? 

[1’1 I do not remember. 

[1J! Q Do ou remember approximately how bng this 

[ 191 conversation was, Y hat IS, when in bme it was relative to 

[ 20 1 when Ms. Jolle left the White House? 

iii i put my fin 

A {really don’t remember. I would say if I had to 

[ 23 1 really don 9 

er on it, I would say maybe a few months, but I 

remember exact1 when. 

I-141 Q Did you tell hz s. Jolley in this conversation 

[zj;shortly before she was terminated that the President and Ms. 

Page 28 

[ I ; Lewinsky yre N”,ught smooching? 

[21 

[31 

[4! 

AQ ,‘:.I did not tell her that? 

[51 Q Why are ou so sure you did not tell her that? 

[61 A Because Y haven’t seen that. 

[7! 0 Did anyone else see it? 

[El A 

Q 

Not to my knowledge. 

Tell me about your 

[ :i i Lewinsky. You said that she went ge 

rsonal observations about Ms. 

[ 111 an unnecessary number of times. 

ack and forth in your view 

r~rlobserved this? 

Where were you when you 

I::iGeorge 4. 

A When I observed her, I was at the East Wing post 

[ISI Q Atways? 

A Yeah. Tom 

1:76;least 90 percent, 90 percen r 

recollection, yes. I would say at 

, as far as I remember. 

[Ial Q Have you ever seen Ms. Lewinsky in the West Wing? 

I191 A I don’t recall. 

i:yiMs. 

Q 

Lewinsk 

~22 Iwere only in 

[231 A 

r~4Iresponse.) 

1251 0 Would you have remembered seeing her back there? 

[I 1 only person on that side and bein an intern. as far as I 

~2 1 know she was an intern whether s 9, e had a hard pass or other, 

[ 3 1 it would seem odd to me that she would have so much traffic. 

[ 4 1 Although, again, I don’t know what she was working on at 

[ 5 1 Congressional Affairs at the time. 

izl jcuriosity. if anything. 

0 So you wouM see her go towards this corridor into 

i::ithe mansion, which was the corridor that peo le 

~24 lused from the East Wing to o to the West 

enerally 

A That’s correc? sir. 

v&g9 

(251 

Page 31 

IiiWino? 

Q And you assumed that she was going to the West 

.~1 _ 

I3i A 

[41 Q 

Yes, sir, that’s correct. 

Because she often would ask you about the 

: j 1 President’s schedule, about where the President was? 

A 

it; response.) 

(Witness nodded indicating an affirmative 

181 Q 

A 

Anything else that she would tell you? 

; iii respect. 

Yeah, kind of bugging, K you will, in that 

I mean, kind of an annoyance. 

(111 Q 

A 

What do you mean? 

A 

I :: 1 a schedule that t R 

ain she would ask me on the weekends -there’s 

e POTUS has as far as his movements. what’s 

[ 14 1 oing on. On the weekends, I’m not sure if she had access to 

11511 9 or not, but she, again, she would come out and ask me. 

[ 16 1 what time is he coming back from, lets say for example, Camp 

117 1 David. Or, is he back yet; or has the motorcade come back; 

[ 18 1 or has the chopper landed yet;, or where is he in the house. 

I mean, that pe of nfonnation. if you as a staff 

~:~~mernber don’t know tha 1 , I don’t give it out to you. If you 

12 11 have enough rank or clearance to have a schedule, which most 

(XI do, you can read it for yourseK. 

So, on that part, she was a bit of a pest. No 

IS:jdisrespect intended to her but that’s my opinion of her. 

[251 Q You also said that Ms. Lewinsky was not liked by a 

olcstarr Page 26 to Page 31 
I 

1313 

: lot of people. 

Page 32 

A That’s m observation. 

.: Q Tell us a K : 

A 

out your observation. 

As far as her -where I come from, you speak to 

I-folks when you see them. You know, that’s a pet peeve of 

r.mrne. That s the first thing 

_. And s only time she would speak 

s -to me is when s something. Other than that, 

:.she gave you a quick glance and she looked away as though you 

: I! .weren’t there, and she would do that with everybody, as least 

; :: : as far as the Uniformed Division. 

.._. As far as staff members, being observing and 

i I i overhearing them in conversations, vague conversations on how 

1. they didn’t really care for her. I can’t quote them. I 

i I i. don’t remember who. But I remember, you know, you’re sitting 

.. :‘in the hallway and you’re hearing things in passing, she .-- 

: : - ,wasn’t ve 

?i 

much appreciated. 

What were the 

i f I-: as you can remember7 

people’s complaints about her, as far 

A 

if f j of spoiled. 

As far as I can remember, a little snooty and kind 

Far as I remember, now. 

Q Do you remember anyone specificall 

if; :specifically saying somethinq bad about Ms. Lewrns K 

any person 

y? 

._,. .-1 A Anything bad. 

_--. Q Not necessarily what the person said. 

BY Brian Henderson, 3113198 

_, 

XUAXf6I 

Page 35 

Iii BY MR. BIT-I-MAN: 

L-‘: Q I asked 

[ 31 had 

r 

ou ever heard tha r 

ou a couple of questions, one of which is 

Ms. Lewrnsky. did an 

7y 

one ever teil 

~4 !you hat Ms. Lewrnsky was in the West Wing. 

;51 A Yes. srr. 

1.51 Q 

A 

Who told you that? 

7 

isi 

That would be Fremon Myles. 

0 Anyone else? 

A That would be Officer Fremon Myles. And anything 

[ :i 1 beyond that, I need to assert the privile 

& 

e. 

[11! 0 Oka 

11: !decision. You shou Id 

That’s fine and I nowthat is not your 

n’t obviously be ashamed or anything 

[ 131 like that for asserting the privilege. 

But the 

ti:ishe observed Ms. ‘t 

uestion is just who told you that he or 

ewtnsky in the West Wrng, right, just the 

[ 16 I rWTES of the peo te. 

[I71 A 

Is that right? 

r18lresponse.) 

@&ness nodded indicating an affirmative 

[:zjthat? 

Q And you are supposed to assert the privrlege over 

I211 A Yes. 

[221 Q How many are there? Can you tell me that? How 

[ 23 1 man 

[24]the XI 

people told you that he or she observed Ms. Lewinsky in 

est Wrng? 

[251 A One. 

Page 33 

. A Right, right, right. As far as specific persons 

:i i staffwise. Servicewise, at this point I need to talk to 

ii j counsel. 

::; Q Okay. 

.:- 

.-. A Just to make sure. 

(Whereupon, the deposition was recessed from 12:17 

IllMAN: We are back on the record. It is 

_--. BY MR. BITTMAN: 

i:f:s 

Q Officer Henderson, the question was who 

cifically do you remember complaining or saying something 

:: 3 : a ge out Ms. Lewrnsky’s personality? 

,. 

.--. A Specificall that would be Officer Fremon Myles. ..j. 

_--. Q Fremon My. yles? 

A Yes. 

.:z-look at you. 

p.m. 

Page 34 

. Q Let me ask you, you said you don’t remember ever 

-!:seeing Ms. Lewinsky in the West Wing? 

-. A I cant recall. 

-4‘ Q You can’t recall ever seeing her in the West Wing. 

: 5 j Did you ever hear, or did anyone ever tell you, that she was 

-i.in the West Wing? 

__: A I need to go back to counsel again, sir. I’m 

? : sorry. 

.-. Q That’s oka You can write that down, if ou want. 

_--. A Yes, I wan r 

Q 

to make sure I have the ques 7. Ion right. 

1 If iwas in 

The question is if anyone ever told you that she 

the West Wing. 

.‘i- .--. A Okay. 

. . .-1. Q If so, what did he or she say. 

‘-I- 

.--, A Okay. 

“Z’ Q Then another question would be, did anyone ever 

i !‘i relate to you, communicate to you in any way, that there was 

:: 3 : a relationship between Ms. Lewinsky and the President. Was I 

: 13: going too fast? .^_, .-*. A No. 

Q We’ll ao off the record. It’s 12:27. ._^. 

.--. A ThanCyou. 

- : (Whereupon, the deposition was recessed from 12:27 p.m. 

i!J:until 1252 .m. 

.-;. 

.--_ h!R. $IllMAN: We are back on the record. 

Page 32 to Page 37 

111 

Page 36 

Q One other oerson? 

A Yes. sir. ’ 

Q Is that rson a Secret Service Officer? 

A Again, I!e IIhave to assert the privilege. 

Q Can you write that question down, please? 

A Sure. 

go out to ask them that, 

rson; for whom 

I would probably ask some followup questions, 

1: i too, like in what capacity was that person serving when the 

12 1 person observed her. 

So only two peo le have ever told you that they 

::isaw Ms. Lewinsky in the 

151 A 

v&t Wing, is that right? 

To my recollection. 

161 0 

I 7 1 Myles and 

To your recollection. And that is Officer Fremon 

then this other person? 

[I81 A Correct. 

Q Has anyone ever told you that he or she believed or 

I::; had any knowledge of a relationship between Ms. Lewinsky and 

~211 the President? 

A That would be Officer Fremon Myles and that would 

:%ibe purely speculahon and observation. Anything beyond that, 

[24 1 Iwould need to assert the privilege as well. 

:251 Q Okay. Now, is the speculation on Officer Myles’ 

Page 37 

[ 11 part? I’m just t 

[2 iwhat Officer My ‘Ik 

ing to parse this out. Can you tell me 

s told you? 

131 A A ain. I would need to assert the privilege. 

L4! Q O%ay. Did anyone besides Officer M les ever tell 

[s 1 you that he. or she believed or had other knowledge Y hat there 

[ 6 J was a relapns;;. between the Presrdent and Ms. Lewrnsky? 

171 

Q Officer Myles is the only one who ever said 

iii anything to you about that? 

A 

[ :ii recollection. 

To my recollection, that’s it. It’s my 

Q What Officer Myles told you, was that based on his 

I::ipersonal observations? 

A Yes. I wouldn’t say - I would say so much of, 

I :: i that the conversations that we had about the traffic of Ms. 

[ 161 Lewinsk 

[171it on. I J 

going back and forth, I guess, is what he’s basing 

on’t know. But the constant traffic and the 

[ 181 hounding ou know, of the schedule, the arrival, the 

[Isldeparture’ K’ IS whereabouts. I can’t say that he saw them do 

[zo Ianything or whatever. 

[211 But, a 

[z? 1 were constantly 4 

an. we’re talking about two offtcers who 

ounded about her wanting to know the 

r23lscheduling. So that’s what I base that on. 

I241 Q 

[ 2s 1 brt. 

Okay. You actually sort of confused me a little 

You said that whatever Officer Myles told you - I’m 

olcstarr 
1314 

esA Brian Henderson, 3113198 XMAX(7) 

Page 38 Page 41 

: : : not going to ask you nght now - but whatever Officer Myles 

:::told you about his knowledge or information about a 

[ 3: relatronshi 

I 4 : on Officer & 

between the President and Ms. Lewinsky was based 

vies’ personal observations? 

A Okay. I think I was more or less bnngrng to her 

‘f; attention the unnecessary traffic. for one. And as far as 

.3 : anything else is concerned. what I rcerved as a power kick. 

::: 

: 5 1 traffic. 

So, ou know, Jocel 

It’s on r he weekends w 

:10: At that time. a 

[I 1 Iwith me. He was not in w 

ain. he was posted in the East Wing 

; 12 1 really know. 

e West Wing. So, he would not 

[I?: 0 

To my knowledge, now. 

Oka 

A The !a 

Well, what did Officer Myles tell you? 

ct that, something that we both knew, the 

i:z:fact that she would agarn. if I would take a break or what 

: i6; have you, she would come u 

i 17!ask htm. inquire to the POT Ip 

to him and approach him and again 

S, the President’s schedule, his 

[ 1 a 1 whereabouts, his arrivat/departure times, where he was at in 

:19]the White House, his location, things of that nature.,which 

: zo 1 got to be krnd of a houndrng or a nursance. When IS he 

[ 2 11 coming back?” “Is he back ‘? Et cetera. 

171’ Pretty much the same thing that I already knew and 

;s;jthat I was getting, and he received the same, the same 

124 1 inquiries from her. Ms. Lewinsky, that is. 

‘?Ei L-d> Q Okay. So, you both thought separately that the 

Page 39 

[ 11 tri 

I$ 

s that Ms. Lewinsky was making back and forth to the West 

12 1 mg were inappropriate for someone of her level? 

:31 A In my opinion yes. 

(41 Q And that ou both speculated that there may have 

[ 5 1 been some relationshrp f!e tween the President and Ms. 

[ 6; Lewinsky? Without knowing any facts, you both speculated 

I 7 I that? 

ial A Yes. 

19: Q Okay. 

i0: A May I add something? 

il: Q Absolutelv. ._j A I might also add that the b‘ 

I;ican’t stress this eno 

gest thing, and I 

: 4 1 on a power kick. Tha ?s besides the, you know, speculation 

h. was the fact that 9 thought she was 

: 5: of the relationshi 

16!ranks, whether s 1 

It was more or less goin 

e was to deal with any sta 8 

up in the 

member on that 

:: : side to get where she had to go. 

13: Q Has an 

191 the President and Ms. ‘i 

one ever told you that he or she observed 

A 

ewrnsky kissin ? 

20: I wouM need to assert t i? .. 

:21:question. 

e pnvrlege on that 

--,,. _-L, 0 

‘: 3 I Lewinsky? 

Have you ever talked to Evelyn Lieberman about Ms. 

Li ::4; 

.- 5: 

_ A No, sir. 

Q Have you ever talked to Evelyn Lieberman about 

Page 42 

Q 

li ibecause you felt some 

But did ou fear, and did you warn Ms. Jolley, 

&- 

A 

rng might happen to Ms. Jolley? 

!31 No. I mean, this was something that I would 

~4 1 probably do with any coworker, per se. 

:slwasn’t a big wa.rnrn 

I mean, it’s not, it 

per se, ou know, of you are 

: 61 

; 7 1 & 

et fired, anythrng II 9, e that. 70 t s more or less, you ti 

oing to 

eep your ears, your eyes and 

now, 

13 1 this position and make sure tha r 

our ears open; you just got 

rslpeople. 

you stay on top of your 

Page 40 

[I 1 Jocelyn Jolley? 

i-‘: A No, sir. 

!31 Q Have you ever talked to Betty Currie at all? 

14: A No, sir. 

Q Why did you sug 

i 2 i words or effect, watch her back 0 

est to Jocelyn Jolley that she, in 

what you were concerned 

i 7 1 about was Ms. Lewinsky’s traffic back and forth to the West 

[ 9 1 Wing? 

(9: A 

: : o; Ms. Lewinsk 

Again. in my opinion, I think that, I believe that 

: :I 1 back and fo x 

was on a power kick. And as far as her going 

h like that, rt was high1 

1z: to go back and forth. Again, I don’t x 

unusual for an intern 

now what the work 

13;power was, but it was on a weekend, most of the times it was 

14 I on the weekends. 

151 In the workplace, even in my organization, you have 

:9:folks that go over your head. There was a supervisor. 

171Thouqh it should maybe have not been my place, I do have a 

?9 !conscience. But basicall 

19: 

Ii! 

et ahead any way possi -i le - and these are not facts that I 

I would say that she would try to 

cl01 now,. this is only pure speculation of what I observed - 

I 1 Ieven d it meant stepping on Ms. Jolle or an bod else. 

Q So were you wamin 

i: 1 activities of one of her employees? 

24 j Joke 

g$ls. 

r were ou warning Ms. 

iy 

Jo? aiout,the 

that something may happen to Ms. Jol ey because of her 

2 5 :emp oyees? That’s where I’m confused. 

Page 43 

::s;don’t - it’s ‘irst manners. 

d Did you tell anyone else about your observations 

iii i about Ms. Lewinsky? And these were your observations and 

: I 3 i what you concluded from them, did you tell anyone else 

i I 4 : besides MS. Jolley? 

i:51 A Yes. 

:I61 Q You obviously told Officer Fremon Mytes? 

[173 A Yes. 

. . .* 3; Q Did you tell anyone else? 

!I91 A At this point I will need to consult with the 

:: o 1 attorneys on that one. 

;?I] Q Okay. We have three questions pending. I may 

i?? lactually go with you to sort of frame the issues for them 

:z3lbecause we are near the end. 

;24i That is, I would like to know the level or the 

~2 s 1 background of the person who told you that he or she saw 

OlCStarr Page 38 to Page 43 
1315 

q SA 

Page 44 

Brian Henderson, 31398 

Page 47 

XMAX(8) 

[ 1 j something. or may have seen something between the President 

rz 1 and Ms. Lewrnsky. Not identify the erson b name but 

i 3lwhether the oerson was a Service 2. ervrce 0 k rcer. or 

I I 1 a short break. 

121 A Okay. 

131 (Whereupon, the deposition was recessed from 1:07 p m. 

;;;until 1% pMm:) 

R BITTMAN: We are back on the record. It is 

16]1:% p.m. 

171 BY MR. BITTMAN: 

181 Q 

lslthat 

Have ou told anyone else about the observations 

ou made about Kn 

?ojWes r 

s. Lewinsky goin back and forth to the 

Wrng. other than Officer Fremon F4 yles and Jocelyn 

2 11 Jollev? iz_-i - A Yes. 

[231 Q 

A 

Who else havepu totd? 

Vanous other o icers rn passing. Or I should say 

li:iactually a couple of offken. And also coworkers at the 

Page 45 

[ 1) East Gate, which is also a part of the East Wrng; supervisor, 

[: )a couple of supervisors, or at least one. 

Q Do you remember the names of these other pew, 

/: i that is, these other offken, these coworkers at the East 

i 5j Gate, and then the supervisor7 

A The coworker at the East Gate would be Officer 

i 7”; Karen Edgerton, E-D-G-E-R-T-O-N. The supervisor would be, if 

1 B 1 I’m not mistaken now, I believe at the time it would have 

f 91 been Sergeant Michael Redwine. I believe he was still my 

r I o I seroeant at the time. And there mav have been a couple of 

[ 1: jothers in passin . I don’t recall the names or faces. 

1121 Q b?‘hat did you tell Officer Edger-ton and Sergeant 

i I 3 j Redwine? 

,141 A Basicallv - Seraeant Redwine pretty much had an 

i ;5 i understanding or an idea, the came conclusion thai. you know, 

[ 16]She’S goin back and forth and it was ettin to be qurte 

[ i 8 1 ser ean in charge of the house itself from my secbon. I 

! ;7 1 an yin? _&cause he was the East W%gdest Wr?glMansion 

!lglthrn , I’m pretty sure it was him. I had a couple sergeants. 

And as far as Officer Ed erton was concerned 

i;yiagain if my memory serves me rig P, 1, she may have been 

r2z)working at the East Gate at times when Ms. Lewinsky would 

(23)come to work on the weekends and be b herself, or maybe one 

i24 lother staff 

ge 

rson in that win 

!251 

[ 11 observations of her? 

Page 46 

A Well, yeah. It was more or less. oh. by the way, 

1; i she’s in kind of late again, isn’t she, you know; yeah. she’s 

[ 4 1 bu 

? 

ging me again about the arrival, or whatever, along that 

!5]na ure. 

Q 

1; i that you know of to be delivere 

Did Ms. Lewinsk ever have any packages or cards 

dy to the President. 

181 A 

Q 

No. I don’t know of any. 

191 Did vou ever hear of her ever delivering any 

[i 0 i packages or cards? 

_ - 

;:;;first. 

A Other than what’s on television now? No. It’s the 

I131 MR. BITTMAN: Lets go off the record for a moment. 

I141 

1151 tK%. %%!&N: 

Q You indicated Officer Henderson, that there was 

1:;; another person besides Off&x Myles who told you that he or 

[lslshe saw Ms. Lewinsky in the West Wing. Is that right? 

1191 A Yes, srr. 

[201 Q 

A 

What that person a Secret Service Officer? 

[211 

Q 

At this point I would have to assert the privile 

[221 Can you tell me anything about the dentity o 3 

e. 

that 

r:3lperson? 

i24j’ A No, sir. 

[?51 MR. BITTMAN: Can we go off the record for a moment 

~__~__~ 

Page 44 to Page 49 

Officer Henderson, has anyone ever talked to you 

said - about a 

: E : possible relationship and Ms. Lewrnsky? 

._. 

. 1 A Yes, sir. 

.:- L-_ Q How many ople? 

.5‘ .-. A That would ge a possibility of at least two 

j : 2; persons. 

,. . 

,--_ 0 Two persons? 

I_^’ ,--_ A Speculatrng. Yes, sir. 

.. _- 3. 1 Q 

:::: A 

Who are those two people? 

Q 

A ain. I will have to assert the privilege. 

That these peo le told you about a possible 

ii ii relationship between the Press -8 ent and Ms. Lewrnsky, you said 

: : -i it was soeculation? 

ii3f ’ A In my opinion. sir, yes. 

[?3: Q In your oprnion it was s culation? 

I?^’ “‘ 

Q 

If I couM correct mysel 

i::: 

Ifi i ~esiden~~nct Ms. >mr nsky? 

R” Well, go ahead. 

ople’s 

The uestion is, was it speculatron on these 

art who to d you about a relationship between the 

r::: 

!251 

A I don’t know: 

Q You don’t know? 

Page 48 

[I! A 

Q 

I’m not a hundred percent sure. 

Did these ople when they told you about this 

1’3 1 possible relationship, did Pe hey relay any facts to you or 

r: 1 alleged facts? 

;5: A I would need to talk to counsel on that question. 

161 Q All right. and let me make clear the distinction. 

I don’t want to know if an one just said, sort of 

j z ; like Officer M tes did 

A ‘Yes sir! 

ou’ve alrea r!{ 

1 ;;go back and orth lust Ike you saw 

said this, he saw her 

er go back and forth. 

[:3! 

Q You know she’s going back and forth an awful lot. 

I ii 1 Ithink there may be something oing on.” That’s 

l;3?e 

culation But it also IS base 8 

11 J : o servabons of people seein 

on some personal 

1151 back and forth to the West \hp 

her, thinking that she is going 

rng,, and also her talkrng to you 

116 1 a lot about where the President IS et cetera. You have some 

[ :-: basis to speculate, so to speak. But there are some facts 

[::,:there. 

113: These two persons who told you, is one of them 

[ 2.2: Officer Myles? Or are these two others? 

[ : : need to consult with the attorneys. 

iZ] 

Page 49 

0 Okay. 

A And your next followup question to that, if you 

I: j would, please? 

Q Sure. My followup question wouM just be the 

: z j identity of those people 

:71 A I think. rf I’m not mistaken, I stated Fremon Myles 

i 2 i and that was, from my point of view, speculation on his part.. 

! s!And the other person, I would need to consult with the 

[ 1 c; attorneys. 

Q Okay. So, there are two people. Can you tell me 

! ti {whether this other person who relayed this to you is a Secret 

i I3 j Service Officer? 

[Id; A I would need to invoke the privilege on that one, 

[ I 5 1 sir. 

0 Oka Can you tell me whether this other person 

~~~~personally;bs~~:it 

[??I A A ain, I would invoke the privilege on that, sir. 

1:s; 

;::j,:,,. MR. BlT%lAN: Let’s go off the record. It is now 

(Whereupon, the deposition was recessed from 2:05 p.m. 

[?iuntil2:17 pMm:) 

$;2:17. 

R BIllMAN: We are back on the record. It is 

~____._ __ __ 

OlCStarr 
1316 

BSA 

Page 50 

Brian Henderson, 3113l98 

Page 0 

XMAX(9) 

BY MR. BITTMAN: 

was the last ques*Xn? 

Not that I remember. 

Q The information that was revealed to you by this 

:ilotner person who saw Ms. Lewinsk? in the West Wing, was that 

14’ths personAs personal observations. 

15: On that one, I have to invoke the rivilege. sir 

1E: Q And that is this ptivile e identih 

i 7 1 function privilege? Is that how it has %een dese8aspmtedNe 

~l~~ycu? - 

,lcA A Yes. sir. ,--_ 

Q Has’ anyone not in the Secret Service that IS. 

i zt i untfoned or Secret Service a ents, 

[ 22: Seqet Service, ever told you t ‘2, at he or she observed the 

someone outside the 

I;; j hsldent g=nao;sir, 

[75: - Ms. Lewinsky? 

Q Oka 

MR. B&MAN. We can qo off the record. That’s all 

at 2:25 p.m.. the deposrtron was concluded 

-_ 

:. 

. . CERTIFICATE OF COURT REPORTER - NOTARY PUBL 

_. I. Ekzabeth A. Eastman, the officer before wnom 

: 3 : the foregoing deposition was taken, do hereb 

Y 

certify that 

: ?:the witness whose testimony appears in the oregorng 

: :: jdeposrbon was dul 

.:: !witness was taken II 

sworn by me;,that the testimony of said 

: 1: 1 to 

y me electronically and thereafter reduced 

::3jof x t 

pewntrng by me; that said deposition is a true record 

e tesbmony given by said witness: that I am neither 

.:: : counse! for, related to, nor employed by any of the parties 

-:s:to the actron in which this depositron was taken and. 

: : 6 :further. that I am not a relative or employee of any attorney 

::‘;or counsel emplo 

: 2 1 otherwise interes r 

ed by the parties hereto, nor finanually or 

ed in the outcome of the action. -7 

.-31 

.^L( 

.-2, 7Ht 

._. DISTRICT OF COLUMBIA 

iss j My Commission Expires: 

:13jJuly 31, 2000 

‘-4; 

i:51 

Page 51 

cl: A No, sir. 

Q Has anyone in the Secret Service ever told you that 

15: he or she observed the President and Ms. Lewinsky kissing? 

14: A No, sir. 

15: Q No one has ever told you that? 

!6: A No, sir. 

Q Do you remember that you asserted the privilege on 

i i j that question earlier? 

A No, sir. If I’m not mistaken, I thou 

[ ii I berng specific as to specific individuals. one of w f? 

ht you were 

rch I did 

[ 11 inot name. You asked a broad 

! 12 1 there is no basis in my mind. X 

neral question. Therefore, 

e Secret Service is huge, 

I :: i 5.000-stro%. BITTMAN: I think we can conclude now. 

115: 

[IO: 

bD&u;.s@Gk;$, record.) 

i:,. Q This person who rela 

i I 9 j observed Ms. Lewinsky in the West &J 

ed to you that he or she 

rng, when that was relayed 

E i 9: to you, was an one else present? 

c:o: A !ll have to invoke the privilege and not answer 

(2: j that question, sir. 

Q You are going to invoke the pnvile 

jiilor not anyone else was present when this person 

e as to whether 

i14; A Okay. Let me make sure I understand 

r35:Say that one once more. 

Page 52 

11: Q You’ve alread 

;2‘wno told you that he or she o i 

indicated that there was a person 

served Ms. Lewinsky in the West 

r3:Wlng. _ 

c:: A Yes, sir. 

Q When that person told 

i ~;was. was anyone else besides 7 

ou that, whoever the person 

A 

yourse f present? 

Not that I recall. I don’t remember though, but 

ilj not that I recall. 

[S: Q Not that you recall? 

[lOI A Yes, sir. 

Q It was just you and whoever this other person is, 

I :i i and he or she told you whatever he or she had to tell you 

1 l3!awut Ms. Lewinsk bein 

[14; A As f%r as ? 

in the West Wing? Is that right? 

remember sir that’s correct. 

115: Q And 

! 16: that conversation. 

ou said you haven’t told anybody else about 

o r 

[l:: A 

her than your attome s? 

As far as I remember, sir, tXl at’s correct. 

[is: Q Okay. As far as ou know, has this other person, 

rson who ave you the in ormatron about the observation 

;“%%&~&n;ky%e 

7 

rng in the West Wing, has she or he toM 

1: 

[I:: A I do not know, sir. 

[23: Q 

A 

Have you heard that? 

Iiliheard it. 

No, not that I’ve - I’m not aware. I have not 

olcstarr Page 50 to Page 0 
Nancy Hernreich, 2125198 

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 
1318 

as* Nancy Hemreich, 2125138 xyur11 _____ 

Page 1 

I:: UNITED STATES DISTRICT COURT 

FOR THE DISTRICT OF COLUMBIA 

[2!_____ --_____ ____x 

i:iln re: 

I Z; GRAND JURY PROCEEDINGS : 

[7i 

[*]_______________-x 

191 Grand Jury Room No. 4 

1101 United States District Cou’ 

[Ill for the District of Columbia 

+i “._ a _ Constitutic _. tn. N.W. 

114; 

Washington, DC. 20001 

Wednesday, Februa 25 1998 

1151 The testimony of NANCrHEkNREl 

[ 16 1 presence of a full quorum of Grand JUI 

r I 7 1 on September 19. 199 

I181 DAVID BARbcr 

[I91 SOLOMON WISENI 

iZOl MARY ANNE WlRTH 

CH was taken in 

ry 97-2. impanekd 

!L,_rmmencing at 1:40 p.m., before: 

BERG 

.--1 

I211 

I221 

[231 

I241 

I251 

Associate Independent Counsel 

Office of lndepdent Counsel 

1001 Pennsy anra Avenue, Northwest 

Suite 490 North 

Washington, D.C. 2ooo4 

the 

Page 2 

(11 PROCEEDINGS 

[z]Whereupon. 

NANCY HERNREICH 

1 :i was celled as a witness and, after being first duly sworn by 

[ 5 1 the Deputy Foreperson of the Grand Jury, was examined and 

[ 6 1 testified as follows: 

I7! EXAMINATION 

[Gl BY MR. BARGER: . 

191 0 Good afternoon. 

L-_ 

[lo; A Good afternoon. 

[I:’ 

ill; 

0 

A 

Could you please state your name for the record. 

0 

My name is Nancy Hemrerch. 

And could you spell your last name for the benefit 

i i: i of the court reporter please. 

[:5. A It’s H’e-r-n-r-e&c-h. 

116 0 Ms. Hemreich, you are here today pursuant to a 

1: 7 : federal GraAnd J;rnrsubpoena, correct? 

(1s. 

5 0 Could you tell the members of Grand Jury - 

; i 0 i actually. let me - before I get into the substance, let me 

; : : ; just do a bnef bit of background on. 

Pursuant to the Grand Jury subpoena you have been 

j 5; jsubpoenaed to provrde infomtation in a federal Grand Jury 

: :; : rnveshgahon concemrn 

: 2 5 ; Monica Lewrnsky and o 9 

possible criminal offenses by 

hers, as a general background matter. 

___~_. _.___ - __-- 

Page 3 

; : ! Do you understand that? .^. A Yes. 

ave a right to have 

W-h-e-a-t? 

Yes.. _ 

1 

I181 n 

I191 Q And Mr. Treanors name IS - 

I201 A 

[:I! 0 

It’s Gerald Treanor.,and it is T-r-s+a-n-o-r: 

t 2 2 1 is you have the 

Oka One of the nghts you have in havmg counsel 

h! to consutt with counsel, should you 

[ 2 3 ] choose to do so. % o you understand that? 

1241 A Yes. 

I251 Q So that if you need to take a break and consult 

Yes. 

In fact, are you represented by counsel today? 

Yes, I am. 

And is your counsel outside of the Grand Jury 

Yes. 

Who are you represented by? 

I’m represented by Gerry Treanor and by 

Page 4 

t I ]with counsel, stmply let us know, and we will provide you 

I : 1 that opportunity. 

13: A Okay. Thank ou. 

14: 0 In addition to K avrng the right to counsel, 

15 1 ou also have a right to not answer any question a 

16 ,r 1ruthful answer to which would incriminate you. Do 

I 7 I vou understand that? ._ 

1:; 

A Yes. 

Q In addition to our ri 

10 1 obligations. The main obliga r B 

hts. there are certain 

ion, o 

111 been sworn under oath, 

course, .is havin 

i 

ou have an oblgatron to te B the 

12 J truth, to the best of your 

13]understand that? 

nowledge and belief. Do you 

141 A Yes. 

151 (1 And !, you don’t tell the. truth to the best of 

[]6]your knowledge and Delat. you couro pa prosecute$! ror 

1 I7 1 various criminal offenses, such as 

[ 18 ]juStiCe - tpgsyzng those lines. K 

nuty, obstruction of 

you understand that? 

Page 5 

[II Q 

A 

And how long have you held that position? 

I’ve held this position since January 20. 1993. 

i:iThe title changed at some point - I think in Se 

[4 1’94. That’s ap roximate. I could be wrong on hat. But - 

& 

P 

tember of 

[ 5 1 but it’s basical been the same ‘ob. 

0 

i ,” i have essential1 

All right. Regard 1 ess of the tile. the duties 

been the same? 

[Gl A {es that’s ht. 

191 0 Could YOU te “9 I us brie% what those duties 

[iojgenerally are. _ 

A I manage the immediate office of the President and 

t :: ;supervise that staff of nine other people. And I act as the 

[ I 3 1 President’s gatekeeper. 

[?4! Q Now, you used the phrase “gatekee 

[ 15 1 curious - is that a phrase you came up with, or is t R” 

r: I’m sort 

at 

I ~61somethina that someone used to describe the position 

i I 1 j previousIf? 

A Well I think the first person who described that 

1 :ij o&on for me or described me as bein 

& 

the 

ack McLarty.‘who was at the time the c ?i ref o s staff to the 

atekeeper was 

[~OI 

1: 11 President. So I’ve sort the taken it on and used it. 

0 

i zz! aooroximatelv Januarv of 1992 is that correct? 

All right. Now ou came to the White House in 

A - Yes, that’s correct. 

Q And was that in connection with the election of 

Page 6 

I I 1 President Clinton as President? .-1 

I21 A Yes. 

Q Prior to Mr. Clinton being elected as President, 

f : ; did you previously work for him when he was governor? 

151 A Yes, I worked for him when he was ovemor. 

161 Q And can YOU tell us approximatelv. a believe - was 

i7jthat comm~cin in about 1985? 

IRI As. that’s tioht - 19;;. 

L-1 

0 Can you tell ‘us what 

I : ,’ 1 qovemor comrnencina in about 198 so ? 

sition you held with the 

illi- A 

Q 

I was fiis scheduling secreta 

Briefly how would you descn 

! :: t comoared to the one vou have now? 

%e that position, say. 

A Then I- you know planned and basically executed 

i : : i his entire schedule. You know, made the decisions in 

[ 16]conference with the chief of staff - what he was 

[ 17 ] and who he would see and, you know, made all t R 

oing to do 

[ 1 B 1 and logistics for it. 

arrangements 

Now lmana eastaffof-youknow I-l 

~:~~would describe’ primari a as you know secreta~l work. 

(211 I think we - we’ve - we take care of P’msident’s sort of 

122 ]daily needs, in terms of his phone calls and handle his 

[23~ames 

P 

ondence. And then we execute his dai 

2 

schedule. And 

~24 ]: but don’t do the planning for the schedule, II e I did 

[251m Arkansas. 

.--.~ , 

I 

---.-- .__-___ 

OlCStarr Page1 toPage 
1319 

BSA Nancy Hemreich, 2125198 XMAX(D 

Page 7 

Q Okay. So taking up the last part of your testrmony 

Ii 1 that you just fintshed. if I understand you, marnly. you’re 

[ 3 lmore ,concqned with executing his schedule. as opposed to 

;;; plannmg hz dai&;.chedule - 1s that a farr statement? 

I61 Q Okay. Nov. ,you mentioned there is a staff. 

17 1Are you basical 

r 

- I mean. & 

the admmlstrator of that staff, or are 

re do you fit m the charn of command, in 

it! &ks of the staff you were discussing that helped execute 

[lo)his schedu/? 

Ill1 I’m - basically. I’m the administrator of the 

[lrlstaff. Thag arrect. 

(131 How many people do you supenrise? 

I141 A I supervise nine people. 

[I51 Q Can you give us a brief overview of - not 

[I 61 necessarity yet who those peoples names are, but sort - 

I 171 of the cham of command - what their posrtrons are, that 

[ 18 J kind of thi;g_ 

[191 Mm-hmm. 

Q Is it you at the top with nine people equally 

i:ylanayed, or is there a further hierarchy? 

I221 A Well, there’s a - a little bii of a hierarchy, 

(231 I think. We have a division of it called personal 

124 1 correspondence. and then we have 

r25)charge of personal correspondence. 

somebody who’s in 

Page 10 

Q Can you tell the Grand Jury as best you recall, 

iii when the first time it was that you became familiar with the 

[ 31 name Monica Lewrnsky. or the 

[ 4 !we need to distingutsh. we can. 

person Monica Lemnsky. and if 

A 

IzjMonica Lewmsky was in the chief of staffs o 

The first time I can recall havir# seen. 

I 7 1 the government shutdown. 

ce dunng 

I81 Q Do you remember approximately when that was? 

[9! A I don’t remember when that was. 

I101 Q Do ou remember what year? 

Ill1 A We x , In remembering - no. I don’t remember what 

[ ~zlyear. but I think it was - you know, In going back, it’s 

tl3lprobabty late 1995. 

1141 Q Okay. Approximately the fall, wouM that be fair 

[ 1s ] to say - somewhere around the fall of ‘95? 

A Mm-hmm. Late fall because at some point 

i :7”; in the government shutdown I remember that it started 

rlslsnowing - in one of the shutdowns. So it would have been 

[ 19 1 late falf-eariy winter. 

I201 Q Why does that time stick in your mind? In other 

r211words. what was rt that you recall about Ms. Lewinsky that 

I 22 ] caused you to remember her? 

A 

I::; It was just necessary personnel. 

Well, there weren’t ve man people working then. 

An 2 then t $hadto-I 

rzslthink interns came in and substituted for extra elp. And so 

Page 8 

(11 So that Ann McCoy is - is the person who’s 

[ 2 1 in charge of personal correspondence. It used to be 

I 3 1 Carolyn Huber There are three people then who work 

rslfor her under there. 

And then I would say the rest of them are all 

/z 1 equally under me. There are (p know, frvegeopfe that 

I 7 I - tt wouM be the secretary an the Presrden s arde. 

i 8 j receptronist, the records keeper. and then 

m& 

assistant. 

Q The Grand Jury has heard re rence to various aides 

[ :,‘I for the President - people such as Steve Goodin. and 

c 1: 1 Kris Engskov. I believe. 

II’1 Aletflosethety 

i I 31 that you supervw. or do t R 

of people that also work for you 

: 14 I suoeNrsron7 

ey come under someone else s 

i15: A 

;iE; Q 

Th~‘re under “j surNision. 

‘:7 : to Bettv Cume. 

An the Grand ury as heard reference before 

: : 5 ! of cominaid? 

Does Bettv Currie come under vour chain 

.:g> 

.?^ 

.I: 

Q 

Yes, Betty Currie comes under my chain of command. 

.--, A 

And so essentiallv. are vou Bettv s boss? 

Yes, I’m Be ‘s boss. s ~’ 

,__. Q Can you tell 1 he members of the Grand Jury, 

‘I? : where IS your office m relation to, say, Betty’s and 

: z; ‘the President’s7 

._lc .-A. A Well. the Oval Office is here, and Betty’s office 

Page 9 

: : : is right outside of the President’s office. And then I have 

: 1. a small offrcQe. real1 off of Betty s office (tndicatrng). 

‘3 

;I’ 

So Lrlv close oroximitv? 

A jj: Yes _ ’ _ 

Q If I recollect, there are no other people with 

; offtees be’;TT”n 

Txat’s correct. 

ours and Betty s office, for example. 

:-. 

;;: Q As I mentioned the main purpose for the subpoena 

i i. is In connectron with a Grand Ju 

::>: MR WISENBERG: % 

investigatron. 

ardon me just a minute. If you 

; : need to. YOU couM out an exhibii sticker on either one of 

j :: : these. so 

b. 

ou could identify it. 

.:3! R BARGER: Oka If you want me to. 

!i4’ MR. WlSENBERG: 

: : 5; them hand 

rdo not want you to. I do have 

m case ou want to. 

liE! &f MR. BXRGER: 

/ i: i don’t 

Q 

have 

Mr. Wenberg agrees with my decision that I 

to have the witness mark the exact office in I--. ~, 

;:g!whrch she w’oncs 

;20: Let me turn now to the main topic of the 

: 2 1) inveshgatron of the Grand Jury - and that is. possible 

;22 1 offenses mvotvmg Monrca Lewinsky and others. 

‘73’ I assume you’re familiar with the name 

i:4;Moruca L~nsk ? 

i251 ? es. I am familiar with that name. 

[I Isince there weren’t very many people around, you certainly, 

Page 11 

(2 I ou know, noticed the people who wete new and who were 

r3)klping out. 

Q Okay. At that time is that what you understood 

I: i her position to be - that of an intern? 

A Eventually. I - I’m sure when I first saw her, I 

i; j probably didn’t have a real understanding of what her 

[ 8 1 position was, but - 

Q Okay. From 

? 

our ObseNation of that time 

[ f ziperiod in approximately the all of ‘95 - is that what your 

I 1 L I observation was, that she essentiallv was heloina out durina 

ilzlthe shutdown? 

. _ 

I131 A Yes, that was my observation. 

I: :;seein 

0 Okay. Is there a next time that you recall 

[16lfallo P 95? 

Monica Lewrnsky after this shutdown period in the 

A Specifically no I can’t sa 

1 :i; particular time I saw her. But i know tha r 

that there’s a 

I have seen her 

[19!_ I had seen her - I have seen her since then, so - 

i201 Q Okay. What is the next incident - and I don’t 

rzllmean incident in any pejorative sense. What’s the next time 

r22)you recall seein her s 

A 

ciftcally after the shutdown? 

l23! dell. le/%e just say that I can’t probably tell 

(24 ithat you that it was a next trme or - but I can tell you 

[251what I can recall generally. 

Page 12 

Ill 

2 %%me I can recall seeing her walk in the 

15 i halfway early in the morning, as we were getting - the 

(4 1 President was getting ready to start going to a meeting in 

[ 5 ] - In the resrdence on the ground floor. 

!76]durin 

And i recall one evenin - and I think probably 

9 

the shutdown one of the s 3, utdowns - and it may have 

r 8 1 been hat first shutdown where she. I think. brouaht some 

i 9 1 food into our office. 

I 

101 Q Okay. 

111 A And then I recall a time that she came to a 

12 1 radio address. 

131 And those are 

II Iseeing her. I think I saw 3, 

enerally the times that I can recall 

er at a social event once, but - 

151and there may have been more, but that’s what my general 

16)=ott=tion_ls. _. _ __ _ 

fnrlthat basically - do I have 

t251 A Would you go through that again? 

_ ---- -. 

Page 7 to Page 12 OlCStafT 
1320 

BSA Nancy Hemreich, 2/25198 Uuxo) 

Page 13 

-. Q Sure. 

._. 

.-. A 

0 

To make sure I go! those ht 

Your,first r,ecollecbon is tha “9. you saw her in the 

: ; i fall of ‘95 ii conYTehron with the shutdown. 

-:: 

:i: Q And the second time, you have a recollection of 

:- jseeing her at some,time - you characterize it as early in 

: 5 1 the momin 

:S: w 

- waa;gzwn the hall. 

. . _. Q 

1: I; radio address. 

And third, I believe you saw her at a 

r._: 

.--: A Mm-hmm. 

Q 

ii:isocial event. 

And then fourth, you may have seen her at a 

I.&’ 

,--, A That’s correct. 

:‘ Q Okay. Any other instances that you recall seeing 

i rt/ her, other than those four - as best you recall? 

A No not - I - t’m sure - oh I’m not sure that I 

jtz;did but you know I certainly may have &an her some other 

i%jtin&. But I do noi recall them. 

[‘:I Q Okay. And that% all - 

I221 

A0 suF 

i Z 1 recollection. 

- I m asking. is to the best of your 

rzsi A Mm-hmm. Yeah. 

Page 14 

i:’ Q Alltight. Let’s obaokbrieft tobriefty to 

;_-jthe shutdown. You menb .onec?sornething agout bringing food 

: 3 1 In. Can you just briefly r&b? to us when you recall 

:c:about mat. 

:5. A lt seems like she brought food - izza or 

: 6 i something in one evening late, you know, 

.- I recollection - 

proba g ly - my 

althouah I can certarntv be wrona about this 

else in connectiin 

.-- I don’t recall. 

8-z __ Q Okay. Do you recalt, during this first time 

-4. ou saw her, whether you saw her rn the presence of 

if : r he Presrdent? 

Page 15 

. A I don’t recall. You mean the very first time I saw 

’ ! her in the chtef of staffs offce? 

I-askrng me? 

Is that what you’re 

1:. 0 Well. in connection with the shutdown. And tet me 

:: ‘make sure I understand you. because when you say you saw her 

.+ In the chref of staffs off&. I take it that when you 

: -. recollect her bnnging plus in, that that may now have been 

: I. a second, or a separate time ou saw her, as distinct from 

: + being In the chief of staffs o f&e. 

; : : : In the chief of staffs office? 

Or did she have pizza 

I.. A I don’t recall. I think you had asked me -the 

i fi ;second part of that, you asked once when I recalled first 

: 1: -seeing her, and I sard in the chief of stStrs office. Then 

1:: : you asked me what other brnes other than that - 

!:s: 

[IL: 2 _“%? t I had seen her, and I said I saw her once 

I 3 - 7when she brought food in to our ofhce. .* 

And so - so I don’t know tf it was a separate day 

ii 5:or not, and you asked me that. and I said I don’t recall 

I 2::whether it was a separate day or not. 

1::: And so - but me 

; 2: 3 my mind - like once I saw L 

were separate kind of events in 

r there, and once I saw her 

(13: here, because the were se 

[zs: MR. WIzENBERg 

rate places. 

David can I ask one question? 

[IS; MR. BARGER: Yes, you bet. 

Page 16 

Cl1 BY MR. WISENBERG: 

Q 

I: i the government shutdown? 

Do you think the food dekvery mcrdent was dunng 

141 A Yes I do think that. 

BY MR. BARGER: 

[I21 Q 

t13jthe shutdown. 

But the same sort of event - the event being 

[I41 A Oh, okay. 

I151 Q Is that fair to say? 

1161 A Yeah. 

0 

I:i{chief of staffs oftice. or brin 

All right. In either instance - whether in the 

I I 9 1 ever see her during the sh up 

ing the pizza in dii you 

tzojthe President? 

down period in the presence of 

I211 A I believe I did. 

(221 AQ $$th~?t, t;;ghk&cg ;r$; gbohat? 

i::ithat during this event where she brought -the bme she 

rzslbrought the food in, that we then offered the food to the 

Page 17 

[ ~1PfesidfM. g well, or he may have been there. But that’s - 

;:;you know.; na&s.quite vague., 

y Well, I.don t mean to suggest there’s 

[ 4 J anything yNy eating ptzza. 

I51 

161 0 lf there is. I think we’d all be in trouble. 

Anything else that you recollect other man 

li ; offering pizza to the President - in terms of her bein 

[ 9 1 in the presenoe of the President? Anything you mea 9. IIn 

I 10 Item-rs of th? rnc$znt? 

Ill1 

[I21 Q Okay. Now, the various times that you have 

[ 13 1 seen her that we just went throu 

I I 4 I more details In the others - are 83 

h - and 1’11 go into 

ese nstances - m 

[ 15 1 question basically is: Have you refreshed your recol L. cbon 

(161recently - in terms of either discussing or reading 

[ 17 I materials about Monica Lewinsky - so as to cause these 

I 1 a I recollections to be recently refreshed - if you understand 

j i 9 1 my questio;? 

[ZOI I understand your question. And the - the only 

121 lone that I’ve sort of - I have - has been. refreshed has 

[22]been the one with the radio address. 

I231 Q Okay. But the pizza shutdown topic is one you had 

(24 ~recalkd without having had your memory refreshed. Is it 

125jfair to say, or - 

Page 18 

111 A Let me just think about it a minute. 

I21 Q Okay. 

A 

/:jlot. that just - 

Because honestly, after a while, and one reads a 

I51 Q Right? 

161 A And you forget - you really can’t distinguish what 

from what you remember and what ou remember 

mai, or somebody says something r o you. 

I101 A And I - let me think about it a minute. 

[Ill 

I121 2 %%er that came - remember the shutdown - I 

r 131 think it’s iust a oeneral memorv. I don’t think 1s been 

i 14 j refreshed b 

cr 

Y&J know, anyotie or any - any readi 

I ::; the shutdown topic o the next - what you describe as t e 

Okay. Letmemovetothenext-gZ?Anyfrom 

117 I next time you recoflected, which iS seeing her walking down 

tlejthe hall earty in the momrn 

[I91 Can p tell us v&at else you recall about that 

jzojsecond genera bme you saw Ms. Lewinsky. What was that in 

t21jconnecbon with? How long did ou see he0 Where was she 

122 jgoing? What was she doing? &at kind of thinq; 

A Well, I mink she was going from r offToe 

i::$robably in krgistative affairs - I assume. And that’s - 

tzsjwalking to something in the West Wrng. Because legistatii _ 

Page 13 to F’ege 18 
1321 

q --. SA Nancy Hemreich. 2/Z/98 

- 

IMAX,., 

Page 19 

Iii 

A No, I did not see where she went. 

Q You did not see whether she went into a 

19 1 particular room? 

(101 A No, I- 

[l?l Q If ou retail. 

(121 A I J on’t recall. 

0 All right. And specitically, do you recall whether 

I::ishe went either to see Betty Currie. or to see the President, 

[ lslor to go into the Oval Office? 

A Let me - I was with the President, who was going 

I :7” iinto a meeting in the Map Room. 

118 Iground floor, and I was in the 

So she was walking down the 

I lgjwhere - I did not see where s 8 

round floor. I don’t see 

Q 

e went, though. 

(201 Oka . And a ain, to be clear, when you sa 

1211 were wtth the President andghe was gettiq ready to go in& 

you 

tzz ~a meeting, were you and President in the 

f23tmeeting going to be in the Map Room? 

ap Room, or was the 

A The meebng was goin 

I: : i were walking from the etevator to the & 

to be in the Map Room, and we 

ap Room, and Ys - 

t I 1 understand my uestron? 

A ?eah. I do understand your question. And I’m 

Ifitrying to go back a& reconstruct R. 

.--, 

[I41 A. Vi. 

[I51 Q So at that time, the necessity to, clear her in 

ests of course. that she no longer ts workrng at the 

~:7”$%?e House. 

[I61 A That‘s right. 

Q As opposed to oing bak to the second time, when 

I:zlyou saw her walking down the R all, at that Ipoint. your clear 

[ 211 snpression is she’s still working at the Wh’ e House. 

1221 A That’sm impression. 

0 Okay. &he didn’t work at the White House in the 

i::l]second incident woufd she be walking down the hallway alone? 

I251 A Say that again. H she did not work - 

Page 20 

[ 1 jthe halhva is what - k’s between us. So - 

i21 L So you and the President are walking down the hail, 

[sland Ms. Lewinsk w comi 

Foxhall - 

A 

the other Way? 

(F&din .)%ell we were walking crossways the 

[6?he ha if 

oing across the?@. Arid she was coming down 

1121 A I can’t put an time period on it. 

[13! 0 Do you recal r, when you saw her walking down 

; 1 .I : the hall, was this a time when she was an intern or not 

f : 5 j an intern? 

[ii: A Well, I can’t - I can’t tell you that for sure. 

[>7‘ Q Okay. You mentioned that your assumption was she 

: :s ‘was walkinAg froym,;;r office. ,1 j. 

.I_. . __... 

.^^. 

I-” Q And I thank you maybe even said in legislative 

;:: ,affairs. Is that - 

!2Z A That’s my assumption. But you asked me whether I 

:: 3 knew if she was an intern or not at that point, and I - I 

i 2 4 can’t tell you that for sure. 

.-: 

a--. Q I understand. But your assumption is she was 

Page 23 

111 [ 2 1 time 

t31wou tJ 

I41 

0 So again, that suggests she was working there at 

Iii the time you saw her walkin down the hall. 

A Well. 1 don’t t 3, ink I ever said she was walking 

Ii;down the hall alone. I’m sorry. 

[91 0 Oh. All right. 

A I don’t mean to be - I don’t recall whether she 

I:yiwas or wasn’t. But, you know I - that second incident. 

[ 12 1 But you’re correct in that if you’re not an employee there, 

r13lthen you shouldn’t - you would not be walking alone. 

1141 

1151 

AQ iz, you recall whether she was walkrng with anybody? 

0 Is there any partiilar reason -why is it you 

i :7” 1 recall Ms. Lewinsk 

[ 18 1 ou and the Pres 

&I 

iJ 

walking down the hall one morning when 

ent were on your way to a meeting III the 

(191 ap Room? Is there something significant that caused you to 

[zolremember that? 

I mean I would imagine you and the President walk 

i$;down the hall fai 

r23lwalking down tht&afl. Why 80 you remember that? 

often and ass many many many people 

A Well - I don t like - this rs my nature I get 

I:!!into. but I think that staff should not be n the hallway 

Page 21 

: .walkin from her office. whrch you believed to be in 

:. leaisla a rve affarrs 

*; 0 The next recollection that you identified was that 

’ ; :of a radto address. correct? 

i._:; A Mm-hmm. 

. . . 

:-a. Q Can you tell us what you recall about that. 

::I: A That she brought some of her family members into in 

i:3 ;a radio address. I think R was her father and maybe her 

[ 14 : stepmother and her brother. 

115) 0 Do you have the time? Do you remember 

116: approximately when that was? 

117; A 

0 

Spring of 1996. somewhere in that range. 

And I believe, and correct me if I’m wrong, you may 

I :z j have earlier indrcated that that particular incident is one 

:201that you may have had your recollection refreshed. 

i2lj A Yes. 

[_‘_‘I Q Can you tell us what you looked at or who you 

123 1 talked with, et cetera, that caused 

~24 ldistinguish between what you r 

ou to - tf you can 

reco lected before and what 

12 5 1 now recollect, having had your memory refreshed. Do you 

you 

Page 24 

111 when the President a in that vicinity and is getting read 

(2 1 to do work. But staff does it, but I normally remember t t; ose 

[ 3 1 people who sort of the cross our paths when we’re. you know, 

[ 4 rn there and he’s in the process of going into a meeting. I 

(51 just - it’s just somethin I remember. 

Q Okay. E? o I take it, then at least one of the 

~76jreasons you remember that is that you ‘felt it somewhat 

18 1 inappropriate for a person in Ms. Lewinsky’s position to have 

fglbeen in t,he hallway when you and the President when you and 

1 lolthe, President are in your way to a meeting - or in the 

11 Ilvianity of the President on ha way to this meeting. Is 

[ 12 1 that generally accurate? 

A Well. I don? - it’s genenlty accurate! but I 

~Ejwoutdnl~t characterize lt as someone R Ms. Lewnsky’s - 

I 15 I as only t ose in MS, Lewinsky position would I have - 

1161someone in her 

Q &$!%t%%ne. for high-tevel staff, you 

~:~~woutdn’t hive tz same hesitation. 

t191. 

;;;;;;aget ro p riate for them thouqht o be that in the my hall “” I wo0k.I - if it was have 

a hesrtation, no matter what level they were. 

1221 Q Okay. You mentioned on the radio address that 

[z3jyou-lbetiiveyouusedthephrase o~bokedupsome 

(24 ]lItfo~ation. CafI yoU tell Us geI%Xat J what 

._ 

tt WaS YOU 

[25]t00ked Up t0 refresh y0IJr recollection about thS radro 

Page 19 to Page 24 OlCStarr 
1322 

1 I 1 address in the spring of ‘96. 

A I asked my assistant to look it up. So I’m not 

iiisure what6he lgked !.I&, is that? 

IZi 

A Rebecca Cameron. 

0 Generally describe for us what it was you 

17 1 instructed Rebecca Cameron to do. 

A I asked her to see what she could find out about 

Iiithat day’s schedule and the 

[loll cleared her in. 

- so that I could ascertain why 

I111 Q What kinds of documents would you expect Rebecca to 

r 12 1 look at to try to answer that question? 

1131 A Well. I don’t know reallv what she looked at. I 

i:. Aa Yeah1: i deared her In. 

- likely what you did, or that’s likely why you 

!4. A Yes. 

ii‘ Q Okay. 1’11 come back to the social in just a 

;z: mrnute. but since we’re talkrng about clearing Ms. Lewmsky 

i:: rn. do you recall whether there were any other times that you 

[ 5: deared Ms. Lewinsky into the White House? 

A 

t:?\cleared her in. 

No, I don’t recall that there were other times I 

11:: Q So to the best of your knowledge, you onjy cleared 

t 12: her in once. 

113: A 

Q 

To the best of my knowledge. 

114: Okay. Let’s go last to the social event. Can you 

[E 1 tell us what you recall about that. What kind of social 

t16:event are we talkin about? 

1171 A You Ir now, I have no idea. 

(161 Q All right. The obvjous question -.I think it% 

[I o; the obvious question - is why is rt then, you think you 

f:ojrecall seeing her at a social event? 

A I just have this vague image of seeing her in the 

~Z~resiclence on the state tloor at some large social event. I 

t23~rnean, jfsomebocly told me, “You never saw her at a sodal 

[24 Ievent at the White House.’ I’d say, “Okay.” But - 

1251 Q You have a vague recollection. 

Page 26 

Q The only point I’m trying to make is to sort of get 

I: i an idea of what kinds of documents Ms. Cameron would look at, 

r31or what kind of information she might look at to solve the 

14 lproblem you posed for.her, which IS, “I signed her in. Look 

[ 51 rnto what 1 may have srgned her in for.” 

I61 A Mm-hmm. Well, I actually don’t know what she 

(7llooked at but - 

(81 Q I understand. But what kind of things would you 

rslexpect - 

A I would assume that she would t 

i iy 1 that day’s schedule. That wouM - and that wou ?d 

to find a copy of 

be the 

[I 2 1 only thmg that I would assume she had probably looked for. 

Q Okay. So when you say that the thrrd incident iI31 

Page 29 

1:: A But I have a vague recollection, I think, of having 

I 2 1 seen her over there. 

Q 

; i 4 1 is the radio address, do you specifically recall seeing 

I: 5 1 Ms. Lewmsky at this radio address? 

[16! A Once that document was shown to me, I do have a 

[ : 7 1 recollection of seeing her there. 

I:; A 

Do you remember the time of year? 

I think it may be around Christmas time, but if it. 

/:,‘=:$]I ou know, that would - because it was indoors; 

y 

17: Q 

thmk d was around in the wintertime, and - 

All right. Other than these four general 

[ 8: categories we’ve covered, are there an other trmes 

[ 9 1 that you recall seeing Ms. Lewinsky? EIe cause that’s 

[ 10 1 been the to ic we’ve been talking about, is times you 

; ;; ; have see &. Lewinskx: 

A I can’t t rnk of any. And that isn’t to say that I 

ou recall seeing her family members - or one 

I 13: haven’t seen her. I ‘ust don’t remember. I’ve seen her a 

; ; : ; jot of television late r y. 

Q Have 

116: A Well, ly believe that I saw them converse the night 

ou ever seen she and the President converse 

I 17~that she brought the food into our office. but - 

(181 Q That’s the pizza? 

113: A 

12c: 

I: : 1 times that 

i 

That’s a va ue recollection - pizza or something. 

All Tht. &ay. So just to be clear, no other 

ou recal seerng her? 

I::;address. but - 

Well, I’m sure they conversed during the radio 

I24: Q Okay. 

125: A But no other - not other than these four times. 

Page 27 

:: .sornethrng?’ and all that. 

[?I 0 I uess my only point is, in your opinion - is it 

j 6 ~correct. then, tha 9 the reason you si ned her in or ckared 

; 4! - I’m sorry. cleared her into the Whi 9 e House was for the 

[ : c I radro address, as o 

A c: 

posed 

[::I Yea 

to some other purpose? 

That’s my assumption, yeah. 

[:21 Q Well, I just want to be - you said assumption. I 

1 i3 Iwant to make clear - IS that what you’re talking about is 

I : 4 1 that It’s your assumption 

[ 15 1 address. or you specifica r 

au cteared her in for the radio 

[l6]her In fOf? 

ly recall, “That’s what I cleared 

I171 A I don’t recall that I cleared her in for that. I 

!: s i have information now that leads me to believe - that shows 

: : 9 1 me that that’s what I did. 

[?Ol Q 

* : 

f;!i Aa 

Oka As you explainedMm- mm. 

!l 

- you had your assistant get information - 

[231 

1241 Aa Mm-hmm. - and based on this information, that suggests had 

I z s I to you that that’s - 

Page 30 

[I !Again, you know, that doesn’t say that I haven’t - 

12: Q I understand. 

r251 Q Okay. 
1323 

_ 

Page 31 

,‘. Q It’s becoming more and more difticutt for him to 

:z !get up here and to schedule anything. 

So I had said to Lanny Breuer in the fall - in 

; : i October or November sometime - I asked him at that time if 

: 51 he could assist me m findin a local attome 

i6: And so actually hr. Ruff had calb and said that 

:71Mr. Treanor would be available, and I was thrilled because he 

; B 1 and I have known each other for five years. 

(slwent to hi h school and 

Our daughters 

o to college together. 

ILO: 8 I’m sony.%r. Treanofs - 

1111 A Yes. 

[I21 0 Oh. okay. 

A 

i: :i Duke together. And he - so I was. YOU know, most pleased 

Other daughters went to NCS together and they go to 

asA Nancv Hemreich, 2125198 xwo 

Page 34 

[I. 

III Aa Mm-hmm. - but when. 

[3! A Oh, it has been since - it’s been in the last 

:P lmonth to fig weeks. 

151 

[6; A I 3 

proximately how long did the conversation last? 

on? recall. Let me - may I step out and talk 

[ 7 1 to my attory fororsecond? 

I61 

19, A Thanks 

r211Mr. Treanor. 

1221 A Yes. 

Q 

I:::said. “Great. I know him.” 

They said well, Mr. Treanor is available and you 

I251 A And I had said that was wonderful. that was 

Page 32 

: I lsomebody who would be acceptable to me. You know, because 

12 1 Lanny had said, “Well. let me think about it and let me 

r3lfind somebody I think that might fit with you and see what 

[ 4;you think.” 

l5i And then when they came and said - I said, “Oh. 

(6 1 that’s perfect, because we have known each other for 

; 7 1 and somebody I like. and 

ears, 

[8! 0 As $0~ un d 

ou know, that’s - I’m deligh r ed.: 

: gjfriend of Mr. Ruff’s 

erstand It. I take it, Mr. Treanor D a 

::0: A I don’t - I don’t know that. 

r.,, 0 Oka What is 

;I_icompensation for NY. J 

our understanding about the 

r Treano Is that something that 

: i 4 ‘L be reimbursed? 

;: 3 1 ou are responsible for. or is someone else, or are you 

: ,.-. A Mr. Treanor is - is 

: : E 3 and we’ll work tt out from there. 

- will be sending me bills, 

..- 0 Okay. But is there any understanding you have or 

j ! : ‘expectation that perhaps you will be reimbursed? 

i A 

i-1, be reimbursed. 

I don’t believe - well, I don’t know that I will 

.-. 0 

I don’t know that you can expect that. 

Well. I understand that you don’t know it, but do 

.!i ‘you have my understandmg or expectatron -. 

- ; Well. I antic! 

:: 1 wtth the Jushce Departmen P 

ate, 

and 

you know, filing whatever I can 

‘2 5 get somethmg back. 

you know, hoptng that I will 

But I don’t know that’s it’s 

Page 33 

: ever guaranteed. 

0 All n 

: I was going to pose %e 

ht. Now, let me go back to the question 

the picture. 

fore the attorneys toptc entered 

; 

You don’t recall having spoken to Ms. Lewinsky. My 

c questron now IS: Exdudin 

- .his associate. Ms. Wheat. R 

your attorney, Mr. Treanor. and 

ave you had any discussions with 

= -anyone. other than your attorneys, about Monica Lewmsky? 

A I have not had any discussion with any -well, let 

- .me just go back I thmk 

: anymore in the ctty abou r 

ou have discussions with everyone 

Moruca Lewinsky. It seems to be 

r. the topic on everyone’s mind. But so, generally, yes. I 

:-have general conversations with eve one. 

0 

i ii j to the specific. 

Okay. We’ll start with r he general before I move 

i:i, A Okay. 

,.-. 0 Perhaps it would be unusual if you hadn’t had some 

j 1~ jdiscusston with someone. 

‘?r.. /.,. A Mm-hmm. 

.-,-’ .-i: Q 

;: : : the Untied 

Have you had an 

States about Monica 

discussions with the President of 

I ewmskv? 

:9- 

.._: A Yes. ,.2. Q Can you tell us when it was you last conversed with 

15; j the President about that to 

es 

IC. 

I 2 5 ! asking you what you talk 

In other words, I’m not 

about yet - 

LS1 

.._ _. 

I101 MR. WISENBERG: Ms. Hemreich - 

I111 THE WITNESS: Uh-huh? 

MR. WlSENBERG: - when you’re done if you would 

i::iknock at the door and then wait for someone to open’it - 

[ 14lwhen you’re throu h talking with your attorney. 

(151 THE Wi?NESS: Oka 

I161 MR. BARGER: Thanlgu., 

(Weiss excused to con 

I:;1222 p.m. y?$l2:24 p.m.) 

r wdh counsel from 

(191 

I201 MR WISENBERG: Let the record reflect that the 

rz11witness is reentering the Grand Jury room and that we have a 

t221quorum. Is that ht Madam De uty Foreperson? 

1231 DE& FOREPERSBN: 

t24 1 need to remind ou that 

Yes it is. MS. Hemreich, i 

ou’re still under oath. 

[251 THE &TINES& Okay. Thank you. 

Ill BY MR. BARGER: 

Page 35 

I21 Q 

[ 31Miss Hemreich or Ms%lemreich or Mrs. - 

I apol ize. I forget how to address you. Is it 

t41 

151 

; 

I61 

~a$i;~;rtco&r;~nM$ny of those. 

A Ms. is fine. hats m - 

[71 0 Y 

rsjname? 

All right. Hemreich, believe, is your married 

191 A Thars correct. 

f101 Q But YOU are - YOU are since divorced? 

rilj 

I121 

1131 

A Corr-ect. - 

roximately when were you divorced? 

AQ %... 

i14j Q Okay. I’m sorry. M 

tlslbreak was how long 1! 

question before we took a 

I 

our convena Ion wtth the President 

[161laSted - at least. tha 

[17]10 be. 

s what I recollect my question 

[lEl A Yeah. It was probably less than a minute. 

I191 Q Can you tell us where it was. 

t201 A tt was in the Oval Oftice. 

I211 0 

I’21 A 

Was anyone else present? 

1231-present. 

I don’t recall that anyone else was President 

0 

If: 1 President initiated? 

Was it a conversation you initiated, or the 

Page 36 

111 A 

t2lattomeys a 

Let me - may I step out and talk to my 

am? 

[31 8 sure. 

I41 A Thank ou. 

t51 Q Sure. I et me -just to save time, I am goin 

[ 6jask you what was said, so you might check with him on tha I 

to 

171one. too. isj A 

[91 MR. BA&GER: 

t’ll robably have to step out again. 

All right. 

(Wiiness excused to confer with counsel from 

::yj2:27 p.m. yrtj 2:30 p.m.) 

,._. 

IiLl 

DEPUTY FOREPERSON: 

I::;under oath. 

Ms. Hemreich, you’re still 

I151 THE WITNESS: Okay. Thanks. 

I161 BY MR. BARGER: 

Q Ms. Hemreich, before we broke, to best of my 

iiii$glFor% President who initia?ed the conversation 

question IS somethin along the lines of: 

rzolthat we e been talking about? That’s my question. 

1211 A 

Q 

KS my recollection that it was the President. 

i::;think you said generally within the last month - is that 

Now in terms of when the conversation occurred, 

j24)fair to say? 

1251 A Uh-huh. 

I 

Page 31 to Page 36 
BSA 

1324 

Nancy Hemreich, 2l25198 

-_ xw*xm -_.__. - ..- 

Page 37 

::‘ 0 olcay. When you say within the last month, is it 

i2’closer to a month. or closer to wkhin the last week? In 

i 3 i other words, tying to 

[ 4 1 the last month. does % 

ive us a general trme frame, ‘within 

at mean approxrmately 30 days ago, or 

I 5 1 does that mean d could have been a week ago? 

[61 A 

0 

I thmk it was closer to 30 days ago. 

t71 Okay. Now, do you recall that on or about - I 

[ 8 1 believe it was Wednesday - on or about Wednesday January 

[ 9!21st, the story concerning the President and Monica Lewinsky 

I IO 1 broke, to use sort of a media term? 

Using that event as a frame of reference was your 

i :: _conversation wrth the President after the story broke, or 

[ I 3 ! before the sto broke? 

114: A rylt was after the sto broke. 

115: Q % 

A 

Okay. How soon a er the story broke? 

My recollection was that it was, you know, shortly 

I:tjafter the story broke. 

[19! Cl 

t19lshort short is. 

When you say “shortly after.” can you tell us how 

I201 A I would - best of my recollection, maybe a week or 

[z1jso-withinaweek. 10da s. 

Q Okay. As Lst you recollect could you tell us 

I::;what the conversabon was about. Who said what? 

A Well. I understand this is an area that’s being 

I::idiscussed. and I respectfully decline to answer it. 

i:] 

Page 40 

Q And Ms. Hemreich - 

;2] A Uh-huh? 

[3! Q Let.me also ask if you will meet with 

14 labout - drscuss wrth your attorney what you are an 6! 

our attorney 

are not 

! 5; repared to answer, in terms of drscussions wrth the 

[6! E restdent. the Sensor presidential staff. and members of the 

~71Whrte House counsels office. so that we will have a 

i 9 1 framework of knowing: Are there different cat ones 

[slof questions that you simply wilt not answer; IS ?I

i io] time-based - is it after a certam period in time; 

[I I 1 and again, these three categories that I gave you - 

t~z~conversabons with the President. conversations with senior 

:13]staff, conversations with members of the counsel’s office. 

!I41 A Okay. 

:I51 Q Thank YOU 

i16i A Mm-hmm. 

1:87;right now 

MR. WISENBERG: And do we want to take a break 

too and ‘ust 

[191 ‘DEPUTYjFO~EPERSON: Yes. 

t201 MR. WISENBERG: A l&minute break, and we will corn 

I 21 Iand get you when we’re ready to reconvene. 

1221 THE WITNESS: Okay. Thank you. 

1231 (A break was taken from 2% p.m. until 2:51 p.m.) 

I241 

l . . 

I251 

r1: 

Page 38 

Q Uoon what basis? 

i;i 

A Eiecutiie rtvilege. 

0 All right. 

, I i the executive oriviteoe? 

R nd who has instructed you to invoke 

isi A ’ M aftome s have instructed me. 

0 & Andlwhat is your understanding about why 

itjyour attome s hav6!instruded you to invoke executive 

f a ; pnvilege? 

j9: A 

abvrous7. they’re not the President. 

Well. - 

[IO] Q Who instructed them to instruct you? 

11:: A S$P+ [ 12 1 to ask them, an 

caky. I think you probably would need 

I d be glad to go out and discuss that 

rl3:with them. 

[:i: MR. WISENBERG: Let me - can I butt in for 

~:5‘a minute? 

[IE: MR. BARGER: 

I. :: if you didn’t. 

You bet. You bet. I’d be surprised 

/_ 

113: THE WTTNESS. 

I 7 5. other well 

You guys are getting to know each 

123: BY MR. WISENBERG: 

, -,. L--_, Q Typically, the executive privilege can only be 

; ~2 irnvoked by the President, Ms. Hemretch. or somebody speaking 

: r 2 : on the Presidents behalf. 

iZ4. A Mm-hmm. 

i?J Q Is rt your understanding that this invocation 

Page 39 

_ _ 

0 Are ou an attorney? 

A No. F m not. 

;1j: Q Okay. I don’t know whether or not you’re 

[ I 4 j aware of the answer - are you aware that there are different 

[ I 5 1 components of executive privilege - different prongs of the 

[ I 6 1 executive privil 7 Are ou aware of that? 

11:: A % I’m noraware of it. 

[15: Q 

[ 19:be invoking 

So’1 take it, you don’t know which prong you might 

- whether it’s presidential communrcations,. 

!ro!national security, something like that. You wouldn’t be rn a 

[ 2 I : position - at least not right now - to tell us which.. if 

r22:any. prongs you’re invoking, or the White House IS invoking? 

123: 

:241 

PQ y,“,y ts;ep out? 

[25! A Thank you. 

Page 41 

Ill MR. WlSENBERG: Let the record reflect that the 

I 2 lwitness has reentered the Grand Jury room. Madam Acting 

i 3 j Foreparson do we have a uorum? 

(41 DEPUTY FOREP%RSON: 

[s I need to remind ou that 

Yes we do. Ms. Hemreich. I 

ou’re still under oath. 

[61 BY Mb. WtSEiGBERG: 

[71 Q I want to ask you one informational question before 

I 8 jwe go back to the issue we were talking about. 

.~. 19! I notice. in addition to Mr. Treanor. there’s 

r~olanother individual - 

Cl11 

8' 

Bnef Interruption to proceedings.) 

(121 Y MR. WlSENBERG: 

1131 Q Let the record reflect that Ma Anne Wkth 

: I 4 1 of Office of Independent Counsel just enter 

:!slGrand Jusroom. 

e&he 

:16i 

I l;lin the hall in 

s Hemreich. I noticed there’s another person nut 

addition to Mr. Treanor. Is that another one 

j 1 B 1 of your attorneys? 

I191 

!101 

1211 

12’1 

(231 

I241 

!25] 

A Yes. 

Q Okav. Is that somebody with Mr. Treanor’s firm? 

A Yes.- 

Q Oka Do you know what her name is? 

A Judi r h Wheat. 

MR. WISENBERG: Okay. Go ahead, Mr. Barger 

_._ .__ 

Page 42 

111 BY MR. BARGER: 

i:ithat 

0 Ms. Hemreich. before we broke I had a question 

enerally related to what the topic of conversation was 

1 Ijwith 9 he President - I mean, what actually was said to and 

[s jwdh the President concemrn 

[ 6)MOnlCa Lewrnsk 

A Mm-hmm. 

approxrma ? ely a month ago. 

thrs conversation you had about 

171 

[El Q, And since that break, have you had an o 

[sjto.consult wdh your attorney concerning. generally, wha P 

portunity 

r~ojpnvrleges you have been instructed to invoke with regard to 

I u I certain toorcs that we mav cover in Grand Jury? 

iizj 'A Yes, I have. 

I131 Q And is it fair to say that Mr. Treanor and I have 

I 14 jalso had an opportunity to discuss briefly sort of the 

115lgeneral to 

[ 16 1 Invoke ml .P 

IQ and how the privileges that you expect to 

relate to these topics? 

j171 A He indicated that. 

1191 0 Okay. Let me try to cover some of that with 

r19lyou now. 

1201 As I understand it, have 

[ 21 I the White. House attorneys. throug $ 

ou been instructed b 

Mr. Treanor. to invo z 

i221certain pnvrleges as to certain conversations that frt 

e 

/ r231into various catwories? 

(241 A Yis. 

t251 Q Okay. Is one of the categories any conversations 

b,c~~~ -_ ._ ~~-__.__ _.___ 

Page 37 to Page’42 
1325 

Nancy Hemreich. 2/Z/98 

._~_ 

Page 43 Page 46 

Ii' In other woros s it only conversations with the 

[ 2 f President after Katheen Wllley story broke. or does it apply 

[ 3 1 to an 

[4 labou r 

conversations you may have had m the President 

i5: 

Katteen Wilkt - if you know? 

I have 10 think about the answer to this - 

. 

1-1 

161 b Okay 

A 

Ilithat is the - is the - Fat from a certain item point to 

- beseuse I’m not sure that iys the time period 

[glnow that isthe rk;or. 

1101 

A 

1:: i.ust have - do you mnd if I think about it a minute? 

But - XI? I think that it may not -well I’ll 

11 

1 

1131 ave to - 

i141 Q All rirt Let me ask you - let me follow up and 

[15]sse if this helps cJar+ the situation. 

1161 A Okay.- 

Q And I won’t 

I:; i Did you have any cuwersa $ Ions wtth the President of the 

t into the content of conversations. 

I 13 1 United States about Kathleen W&y? 

I:iiabout her. 

A Yes, I have had conversations with the President 

1221 Q 

1231 A 

How “any conversations? 

rzslwith him. 

I donl recall how many conversations I’ve had 

1251 Q All rig& You can give us a range, if you wouM. 

Q 

[::;instructed to invoke? 

As you understand it. what privilege have you 

(251 A I’ve been insbucted to invoke 

been 

Page 44 

I 1 J attorney-cl&t privilege. 

Q 

I5 1 believe you testif Ok&$$w$ ~\;tot~o~V - 1 

[4lcolTect? 

. . 

[5l A That’s correct. 

Q And you have not been hired b Mr. Bennett or 

176iMr. Kendall or anybody on their behalf, corre J? 

A So you re asking me if I have bean hired b 

i:lMr. Bennett or Mr. Kendall or by anybody on their beha If/y 

[lOi Q Correct. I? other words, you are employed by the 

[ 1 I lthe White puse, and you re not employed by anybody else. 

[121 That’s correct. 

L131 0 Oka 

1 I 4 ! work for MA Kenda x 

You don’t work for Mr. Bennett. you don’t 

, cprrect? 

!?5‘ 

0 

That’s nght. 

All ri 

i i4 j of their attotne s o f? 

ht. And you don’t fall under the umbrella 

ice correct? 

‘?i‘ 

.--. A ?hat’s cbrrect. 

:19: 0 But, nevertheless..as you understand it, you’ve 

:: 2 ; ken to invoke the President’s attorney-client pnvibge 

::: ,with regard to conversations you had with Mr. Bennett or 

: 22. Mr. Kendall. correct? ,^>. L-I A That’s correct. 

[:;: 0 Oka 

: 2 s :you been lnstructe dy 

Third category: As you understand it, have 

to invoke executive pnvilege with regard 

Page 45 

: : to conversations you have had with senior White House staff 

:‘$ 

rsonnel concemln 

[ 3 : op~c that iccurred a 

conversabons about the Montca Lewlnsky 

a er the story broke? 

[4’ That’s correct. 

:5‘ 0 

A 

Okay. If there were such conversations - 

! 5 

: - : on that? 

Did you - did you say executive privilege 

:i: Q Yes, yes 

,_ 

. +. A 

[I. Q 

0kay;so - 

As you understand it.. the privilegeJou’ve been 

: : : ; instructed: invoke IS execubve privilege, correct. :1-. .a- That’s correct 

iI?: Q And beyond the, term.“execut.ive privilege,” you 

[ ; G idon’t know what kind of executrve pnvitege. rf any, you ve 

i I 5 I been told to Invoke? 

:1ii A That’s correct. 

117! Q All right. The fourth category,, as you understand 

[ 1 s ! it.. have you been instructed to invoke execubve pnvilege 

Ilg!with 

[ ‘0; the Un re! 

ard*to conversations you had with the President of 

ed States concemln 

(21; -A That’s wrre c? 

Kathleen Wllley? 

[_‘I Q Okay. Now, let me follow up on this one to clarify 

[:31a little bit. Do you have any understandin in terms 

: 2 4 I of whether there is a time period. that app P* nzs to 

r25lthat pwlege? 

Page 47 

r11More than one? 

r21 A 

Q 

I’ve had morethan one wnvenation with him. 

01 Less man lo? 

(41 A 

151 Q 

Prob&%&less than 10. 

Okay. 

I 6]fne do it this wa 

kd any of these conversations occur - let 

[ 7 1 the sum?r of r 

: Is L fair to say that in approximately 

997, mere became public stories al 

[ 8 lthe Presdent had made sexual advances at Kathleen @%I that 

A I think mat’s when those -those stories 

I ley? 

(91 

riojwme out. 

[Ill 

1121 2 ?t% was something out about that, because I 

i 13 j became aware of that 

q Q 

tI:jallegations regarding 

When ou say “these allegation,” do you mean the 

R thleen Willey? 

Page 48 

Ill A Yes. 

(21 BY MR. BARGER: 

131 Q Were there any conversations with the President 

[ 4 1 about the allegations mvolving ,hc and Kathleen W&y prior 

I71 Q Okay. So to the best of your recollections, 

conversabons wih the President about the topic of 

r 10 I her occurred 

and the allegations of his sexual advances to 

er these allegations became public - does 

i 1 I j that make sense? 

A 

I::ithink about it a minute - 

It makes tense. but I - you know. and let me just 

[2o]or is that - 

.~~. rzil Q I think so 

1221 A Oka 

1231 BY MR. JVLSENBERG: 

Q When was the last conversation 

12’:iKathleen Willey that you had with the 

ou recall about 

President 7 

Page 43 r0 Page 48 OlCStarr 
BSA 

1326 

Nancy Hemreich, 2125198 

__~I_ XMAXP) 

Page 49 

1 A The last conversation I can recall having, I 

-.believe - and I can’t - it’s certain1 withm the last 

:I-eght months. Buts cific da or ~me I think it’s closer 

4 .to the beginning of tt% time. &~t f&t - I can’t say 

jr.that for certain. 

‘Z’ 0 Okay. Do you recall any of the content - I’m not 

:‘:asking you in this question for the content, but do ou 

:: -recall the content of any of our discussions with 

3’ President about Kathleen V&lie&? 

x, 

r.-. c--. A 

1::: Cl 

Yes, I do recall e content. 

Okay. Tell us all about that - everything you 

I : : : recall about every conversation. 

[:3: A 

Q 

Everythin I recall about eve 

;:4: With the ? resdent about 

,.:. 

.--_ A Oka Are we - prior to the summer of 

[li: 0 Weliy let me ask you this: I had understood 

[ I - : that the executive privi 

;: B :with the President about %a 

e ctatm covered any convenation 

thfeen W&s . Are there soma 

1: 3: conversations with the President about r(, 

[2;:are not covered? 

thleen W~lley that 

12:‘ A Yes. 

132: Cl All tight. 

[23: A As I understand it. 

r24: Q 

[zs: A I m not sure what km o category they fall 

Qkay. In which cat%“! would those be? 

Page 50 

;:: into. May I step out and ask my attorney a question - 

:::take a break? 

‘3. MR. WISENBERG: 

;4:later, Mr. Ba er? 

Do you want to go back to that 

;E: 

,-_ Id? BARGER: Yeah let me - let me - jet me - 

(6’ THE WITNESS: 

:--way of - 

I &an, you might have a better 

14 “: BY MR. BARGER: 

.-. 

[::’ 

2 

!IZi 

Q 

&ta~ ask a different question. 

ill Or ask the same kind of auestion a different wav. 

A Mm-hmm. I. :- 

.-- 0 As I understand it, there were some conversations 

‘. - ou had with the President that concerned the to 

i ::. k athleen W~liey that did not concern the topic of P he 

ic of 

; :4-sexual alle ations - 

,:- 1 Yeah. 

AQ 

correct? 

i-think so. I mean, you know I’ll have to sit 

c ,-- - _ -and think about it. I mean, when 

1:: -have to thank dtd you -was it rea 

ou’re asking that, you 

f - did we sit there 

: 1: ‘and discuss sexual allegations an , you know, that’s where 

: : I you’re getting - was the to ic of - dtd a topic come up 

: I: after sexual altegations - t Re 

!:c t guess they drc. 

sexual allegations came up. 

Page 51 

i < 

And it’s lust how you’re 

makes It seem kke that was al P 

hrasing it. because it 

we were talking about, when 

‘3 that’s - and again. I don’t want to 

:: don’t want to. get Into this area an 8 

o too far, because I 

: 5 what I’m saying? 

- do you understand 

i Its a difficult question for me to answer, and 

il. I’ve been ~tty:;trt,~ming wrth everything. I just - 

‘I 

A Just to say it’s difficult to answer it in a 

1 f I.straightforward way. 

,.. 

,-- Q Let me see if I can just follow up a file bit. 

,.-. 8 _- A Okay. ,.i. 

,-- 0 

: :G drd 

If I understand what you’re saying, are there - 

1 

ou have conversations with the President that concerned 

I : i %e epic of Kathleen Wiltey. but the entire conversat?n did 

[ i 6. not concern the topic of the al 

[:- made sexual advances toward athken W~lley? 

I’:. /-- 

vy that the President 

I mean, in other words, att of the conversation 

[ :?~concemed thmgs other than the a legations of these sexual 

I: - advances. .-- ~~ ~-~ 

12:: A Ma I - ma I step out, just - 

[:Z. BY MR.!&llSENiERG: 

0 Okay. Before we do that, why don’t we switch 

i:i:topics for iminute. 

(15: Okay. 

Page 52 

.: Q 

1; i you’re claiming 

Because I want to get a record DUIR on the thongs 

rivilege. 

!3: A 8kay. 

!4I 0, As I understand it. the White House IS claiming 

: j I execuhve pnvrlege on any conversation ou had with the 

[ 6 1 Preudent relating to Monica Lewinsky a X er the allegations 

[: 1 about the President and Monica Lewinsky became pubkc; is 

[sIthat correct? 

(91 A That’s m understanding. 

Ilo: Q Okay. x 

I 1 I I me President? 

ow many such conferences have you had WI 

112: A 

113; Q 

Only one that I can recall. 

Okay. And you’ve already invoired executive 

[ 14 1 ptivikge with respect to that conversation. 

[151 A That’s correct. 

t161, Q Okay. Now. also I understand that the White House 

[1?]4s,invoking executrve KIT as to any discussron k” had 

1 ls~wth senior staff mem 

I Is~Monica Lewinsk 

rs a out Momca Lemnsky a er the 

matter became public; is that correct? 

1201 A I%at’s correct. 

Page 53 

III A But I can’t - you know, I - without recalling 

~~;~er&in&ie conversation, I - you know, I hate to say 

141 Q Five or less, and probably one cr two. 

I:; 

A Mm-hmm. 

0 And do you remember the content of some of those 

[ 7 1 conversations - any of the content? 

I81 A 

Q 

Yes, I do remember. 

Oka . Who were the converrations with? Which 

r:zistaff members in o r herwords.. 

L111 A ‘Well the ones specifically that I remember are 

I 12 1 conversations with Bruce Lindsey. 

1131 Q 

A 

Okay. An bod other man Mr. Lindsey? 

1141 

(151 Q Pardon d ’ 

Very possi ly o her members of me counsel’s staff. 

A Very possibly other members of the counsel’s 

1:76istaff. Again. I mean, you know-you know I -there 

[I 81 are lots of general discussions - specific cdnversations 

[I 9 j I’d have to go back - but probably most members of the 

t2olWhrte House counsel’s staff. 

121: Q Oka 

I 22~ about the content 

Now, tell us, please, what you remember 

o r each of these conversations with senior 

I z 3 1 staff since the Monica Lewinsky matter became public, 

I241 A Well, tell me what you’re asking me. because I 

[z s I think the content of these conversations is what specifically 

Page 54 

t 11 I want to, you know, assert executive privilege. 

121 Q That‘s exactlv what I want vou to do. 

A Okay. - 

. 

I31 

I41 Q In order for us to have this litigated. we have to 

[ s 1 ask you and YOU have to claim the orivileae. 

,I1 

..Q Sothats what I’m doin 

1; ;content of every discussion you had. 

I want to know the 

& ou said that there 

[ 9 1 mere were five or less and probably one or two with Bruce - 

[ 1 o 1 Bruce Lindsey is the name 

[ i 1 people 0°F cou;.sel s sta !f 

ou can remember, and probably some 

I121 

Q Then my question to 

!::;-uron the content of those conversa tons as you remember 

ou is now Tell the grand 

&he 

ty 

m And do you want to tell us that, or*do you invoke 

Cl6,the privilege? 

i17j 

I181 .--~ 

$ lGza;. to the invoke the privilege. 

1191 A Thank you. 

I201 0 Now, hdw many do you rememkr with Bruce? How 

1211 conversations do you remember? 

I221 A I remember one or two conversabons with Bruce, and 

tz3lagain. it could be more, but that’s what I reme&er right off 

[24lthe m of my head. 

1251 Q All right. I understand you’ve been instructed 

OlCStarr Page 49 to Page 54 
1327 

BSA Nancy Hemreich, 212988 uIu((10) ___~ - __~._ ..-- ~__ _ 

Page 55 

i I 1 to claim attorne -client rivile e for an conversations 

111 cu had with either Mr kennet - Bob &ennett - or 

~31 r. David Kendall; is that correct? 

;‘5; 

A Mm-hmm. That’s correct. 

Q 

A 

Having to do with Monica Lewinsk 

One conversation that relates to My, onlca correct? Lewmsky 

176iwith Mr. Kendall. And I think the other one relates to 

f B 1 Kathleen Willey with Mr. Bennett. 

Cl Mr. Bennett. Okay. There are two - there’s one 

r:ziconversation with Mr. Bennett and one with Mr. Kendall? 

illj A Thars as I recall them. 

Q 

i::ithose conversations. First tell us the content of the 

All right. Tell us the content of the each of 

ii; iconversation with Mr. Bennett. 

A Well I - I would like to assert the i:Z jattomey-client privibge related to that conversation 

[17~with Mr. Bennett. 

Q And now tell us the content of the conversation 

;:89iwith Mr. Kendall about Ms. Lewinsky. 

A I would like to assert attome 

I:f;regarding the conversation with Mr. Kendal r 

-client priviiege 

I221 Cl Now, before we got - and I cut Mr. Barger off 

(231 here. Before we ot kind of lost in the morass of what IS 

[ 24 1 privilege and wha 4. Isn’t on Ms. Wille - and I don’t mean to 

[zslsuggest that Mr. Barger created tha r morass. 

Page 58 

i I 1 knew, besides ourself and Mr. Bennett? 

12: A hot that I’m aware of. 

Q 

i:iWhite House? 

The conversation with Mr. Kendall was at the 

is; A That’s correct. 

Q Was anybody else present besides yourself 

itiand Mr. Kendall? 

[El A I don’t believe so. 

i91 Q 

IlO1 A 

How long did that conversation last? 

Fiieen minutes ma be. 

(111 0 I don’t think I ask erI 

112 ~conversation a roximate 

Ken was 

? 

you, when was that 

113i A 1x1 econversation with Mr. Kendall7 

I141 Q Yes, ma’am. 

I151 A In the last three or four weeks. 

Q Who arranged that meeting? Was that at your 

I :;i request. was that at Mr. Kendall’s request, or was that 

[ I 8 1 someone else’s 

1191 A M!%%‘s request. 

Q 

r[:i;you and Mr. Kendal were present, as far as you recollect? 

I mar have asked - I think I did ask you: Only 

[221 A That’s as I recall it. 

Q Let me o back to the senior staff topic that 

i$:iMr. W&e&erg mve 

I251 The conve%%s%h Mr. Lindsey - I think we 

Page 56 

[II MR. BARGER: Of course you don’t. 

[21 BY MR. WISENBERG: 

Q Are there any other - and I’ll defer to Mr. Barger 

t i i at this point. But are there an 

(51 I do that, let me ask you: Is hx 

other categories - before 

r. Bennett your attorney? Is 

[ 6 1 Bob Bennett your attorney? 

[71 A Bob Bennett is not my attorney. 

(81 Q And is Mr. Kendall your attorney? 

[91 A No, Mr. Kendall is not my attorney. 

!I01 Q Okay. So is it your understandin 

I 111 instructed to invoke the attomey-dient privilege % 

you’re being 

ased on 

[~?lessentialiy the President’s attorneyclient pnvilege with 

113 1 these two lawyers - if you know? 

ill‘ A That’s mv understandina. 

Q Okay. Mow. there are <iy other categories of 

[ i z i privilege that you’re prepared to invoke? 

j17; A I don t thank so. 

:13; 

i:5: 2 

: 20 ; then,, but 

I%% - if it come; up I may you know say it 

ou know right off, without king aiked again ’ 

:r”specifica’!.4k i-2; WISENBERG: 

: I: 3 !questions. I’ll ask IS it oka 

If Mr. Barger doesn’t have any 

r 

if the witness confers with 

::J : her attorney about the Ka hleen Wllley. or are there some 

i 2 s : substantive matters that you want to go over with her? 

Page 57 

MR. BARGER: Let me -there arc a few more, and 

i j. then you want to come back to th;uo$er questions, conect? 

!j’ MR. WISENBERG: 

!:i BY MR. BARGER: 

‘C) 

,-. Q Let me - I’ll deal with, I think, the last 

! t /topic first. 

L-1 With regard to Mr. Bennett and Mr. Kendall, 

: F ‘where did those conversation occur? Did they occur at 

: i-their law offices! or did the 

: : ; 1 White House - if you 

&cur on the grounds of the 

reca x ? I>/. A One conversation was on the tele hone with 

i Ii!Mr. ~~ Bennett. and one conversation with Mr. Ken 8 all was 

.--. f~ 7’at the house. 

!I41 0 The telephone call with Mr. Bennett -were you at 

(15 1 work or were you at home? 

1 

1161 A I was at work. 

Ii71 Q Approximately how long did the telephone call last? : 

iiS; A 

(19jor less. 

My recollection, it was probably five minutes I 

(201 0 

A 

How Ion; ago was that conversation ap 

I! 

roximatety? j 

121: About seven months ago - seven or’eig t 

[zzlmonths ago. 

r - 

, 

I231 Q He initiated the call, or did ou? I 

(241 A Mr. Bennett initiated the ca I. 

I251 Q Okay. Anybody else on the phone, as far as you / 

I 

Page 59 

[I I asked you who, if anyone, else was present besides ourself 

[zland Mr. Lindsey? In other words, were the conversa ty 

r3]between the two of ou. or were other people there? 

Ions lust 

[41 A Can r step out first? 

Q Sure. You bet. 

And I’ll just deal with the other issue, too. I 

[Ill 

I::i3:14 p.m. 

iRG?ka&ase knodc. 

THE WITNESS: Oka I will. 

MR. WISENBERG: I&d we’ll open the door. 

(Wflness excused to consult with counsel from 

$l3:21 p.m.) 

I151 MR. WISENBERG: Let the record refiect that the 

[ 16lwitness has reentered the Grand Jury room at 3:21. Do we 

I 17 1 have a quorum? 

1181 DEPUM FOREPERSON: 

[ 191 need to remind ou’re still under oath. 

Yes, we do. Ms. Hemreich, I 

[201 THE &ITNESS: Okay. Thanks. 

I211 BY MR. BARGER: 

L2.21 0 

it31 I had was: 

Ms. Hemreich, when we broke, one of the questions 

124 lanybody? 

Who else besides Bruce Lindsey was present, d 

I think that was the one of the questions that I 

~251 had. And I think Mr. Wisenberg had another question, but 

Page 60 

11 Iwe’ll deal with mane first. 

And that is: Do you recall whether anyone else 

I : i besides yourself and Bruce Lindsey were present for any of 

1 I1 the conversations? 

,51 .-a A I don’t recall. 

[61 Q 

]7]occurred? 

Okiy. Do you recall where the conversations 

suboffice. as 

A 

I 

I do recall that the conversations occurred in my 

recall them. 1-1 

I101 Q 

[llloccur? 

Okay. At whose request did the conversations 

(121 A I don’t recall that. 

I131 Q Okay. Was it 

A I honestly don r 

our request? 

]I41 recall. 

Q Okay. And I don’t know ti I - I frankly forget if 

:::;I asked you when these conversations occurred - how ncentty 

[17]the conversations with Mr. Lindsey occurred. 

A I don’t recall the specific date or month even, 

i :“,i but it was within the last seven or e’ ht monihs. 

Q 

i:tiinto the content. b 

Ok%. Now, I’m con R sed. I’m not goin toget 

did the conversations with Mr. Lin 8 

i 22 1 wncem Monica Lewinsk , Kathleen W~ltey or both? 

sey 

A 

ii&ink from what -this is an area that I can 

The speci!u one I’m thinkinel%$; well, I 

[ZS]eXeUItiVe pdVi@e on. 

Page 55 to Page 60 

.-. _ 

OICStan 
1328 

esA Nancy Hemreich, 2125198 X~X(11) 

~__ 

Page 61 

III Cl Okay. I’m not gorn to go to the content, but let 

[ 2 1 me explain the reason I’m asking i? because I thought, as we 

[ 3 1 understood it. that the demarcatron’for Monica Lewlnsky was 

[ 4 1 after the story broke - which would have been on or about 

r s 1 January 21st or 23rd. somewhere in that area. 

So given that as what you’ve previously indicated 

1: i as sort of your framework for invoking executive privilege 

(8 1 the conversations with Bruce Lindsey - i’m not goin to ask 

tgjyou the content, but did the conversation with Bruce 8. 

[10~concem Monica Lewinsky? 

mdsey 

A I WOUM like to claim executive privilege on my 

i :: iconversations with Bruce Lindsey. 

I131 Q Even to as to identify the nature of the topic? 

1141 A Yes. 

1151 BY MR. WISENBERG: 

i16j 0 Is this within the - again, I want to ask you: 

t 17 1 You mentioned executive privilege - one of your categories 

t IB lfor executive prtvifege is d4scussrons with senior staff post 

1191 Monica Lewinsky becornin 

Is this Bruce tin 8 

public. 

sey conversation meant to 

i$i;fit into that privite e or is it meant to fit into 

4, tzzlanother privilege. 

1231 A It is meant to 8t into another rivitege. 

1241 Q .& at? 

I251 A 

Okay. And what privilege IS 

A pnvilege post, you know, July of 1997 

ill 

I21 

131 

Page 62 

0 Involving senior staff? 

A lnvotvi senior staff. 

Q Okay. B ut not having to do with Monica Lewinskv - 

i 4 j this particular one?- 

151 A I’d like to claim executive privilege regarding the 

r6lcontent of the conversation. 

[71 Q And the general subject matter? 

161 A And the eneral subject. 

r9i MR. WISEN&RG: Can I ask a few ouestions 

Yes -well, I need to - we need to 

Sure. 

::5i Q You can come back to this. I think it will fit in 

f I 6 1 with the questions I have. 

And that is: In the senior staff topic, you 

: ii i identified five or less and 

: I B: conversations with B’mce p” 

rhaps as few as one or two. 

tndsey. As I understand it, both 

: 2 c 1 of those conversations occurred seven or eight months ago? 

[Z!! A 

Q 

I said within the last seven or eight months. “,‘! All right. Well, within the last seven or 

i I;; eight months, can you be more specific? Did any of those 

: r 4 ) cc%versahons occur within the last month, which-would be 

‘2 5; February of ‘98? 

Page 63 

A That is in the realm of possibility, yes. I 

< 1 don’t - I cannot tell you precisely when any of these 

lace. I don t recall. But there have 

i I that effect. Do YOU recall that testimonv? 

:.3 ..-! A Yes. Ido. 

i:3; Q Okay. And when you sa the counsel’s office, do 

: 1 J I YOU mean the White House counsel’s o a ice? 

[Is;- A Yes, I do. I’m sorry. 

116! Q So generally, who would these people have been. or 

i : 7 I who were these people that you believe ou had conversations 

; : 9 1 wdh that fall under the senior staff execu 

1 

t 19 1 category that we had set out? 

we pnvttege 

IZO! In other words! let me remind you that m 

121 J had to do with conversahons with senior staff abou r 

questions 

the 

r 21 I topic of Monica Lewinskv after the stow broke. 

i23i A Okay. . 

I241 0 

r2slBruce Lindsey. 

And you identified conversations with 

Page 64 

!I: A Mm-hmm. 

:2; Cl And then you identihed conversations with people 

t3] in the White House counsels office 

r4I So now mv ouestion is: Who in the White House 

i j i counsel’s office did you have conversations with, other than 

t6lBruce Lindsey, about this to E: I 7 1 to assert executive privilege. 

ic over which you’ve been told 

181 A I need to - mav I steo out for iust a minute. 

i 9 j please? 

[lOI Q 

1111 

1121 Aa 

A 

- my 

9 

uestion simply is - 

I131 Who e se - yes, I understand that. And then 1’11 

: ii;- then ‘ll %!%&$&G: Before we do that. I have a few 

i i 6 j questions. 

Cl71 MR. BARGER: Yeah, go ahead. 

(181 THE WITNESS: I know. I’ll be brief. I’m sorry. 

1191 BY MR. WlSENBERG: 

i2oj Q 

r21lthe day. 

Let me ask you - we’re going to have to quit for 

r221 

“a Okay. - and ask you to come back at 9: 15 in the 

[::imoming. But before we do that. I’ve got a series of 

r251qwstions i have to ask you for the record. 

Page 65 

Is it part of your duty to advise the President or 

i:;the senior staff on matters of national security? 

t31 A 

0 

I’m sorry, would you ask that again? 

Sure. Is it 

t: i President or his senior sta a 

art of your duties to advise the 

on matters of national 

[6l~Uity? 

A No I do not advise the President or his staff on 

Ii l matters of nationai security. 

Q Oka 

[ii) President or his sta k 

Is it part of our duties to advise the 

on matters o 7 diplomatic affairs? 

I :: i “advise”? 

A Can you be more specitic in what you mean by 

1131 Q Give your - are you one of the Presidents 

[ 14 I advisors who advises him? I don’t - I cant give a more 

I ~s~specific definition than advise. 

1161 Wkhin the Whtte House and how it o 

[ 17 1 are you one of the Presidents advisors on 

rates, 

ma tp” en of 

[ 18 ~diplomaticlforeign-type affairs - diplomatic and/or 

f 19lforeign affairs? 

I201 A No. 

Q Are you one of the President’s advisors on the 

It: 1 Monica Lewinsky matter? 

1231 A In what - no. 

I241 Q Okay. Did your conversation with the President 

1251 regarding Ms. Lewinsky - and I believe you said you had that 

Page 66 

[ 11 one conversation during the time period that you’re claiming 

[ 2 1 the privilege? 

131 A Yes. 

141 Q 

r51secuntv? 

Okay. Did that conversation involve national 

- A No. 

Q Did it involve state secrets? 

A No. 

you advising the President on an 

Okay. Wflti respect to any conversation you’ve had 

I::&h senior staff dunng the time period that you’re claiming 

[ 14 1 the rivilege,, were you have advising senior staff on a 

t151ma tp 

I161 

er of ~tion~t,secunty or state secrets? 

0 

~:~~matters. when you were havin 

And were you advising them on official government 

conversations with sensor 

I 19 I staff, about Monica Lewinsky ? 

1201 A Official government matters? No. 

I211 Q We have to quit for today, but let me remind 

r22jyou that you’re still subject to subpoena. And we will 

1231wntinue tomorrow at 9:15 a.m. And after we break tight 

r24 I now, Mr. Barger might very well speak with your attorney - 

I251 A Okay. Fine. 

ijlC&lW Page 61 to Page 66 
1329 

Page 67 

Nancy Hemreich, 2125198 

-. ___ 

Xhux(12) 

0 - on some of these matters to herp clear them up 

ii ifor the re”Ard, a&on scheduling. I 

i31 

[II MR. WISENBERG: And ma the wtness ba excused? 

:51 DEPUTY FOREPERSON: 4s. 

THE WlTNESS: 

:I21 

*..*- 

::31 

7141 

;:51 

:i61 

:171 

:I81 

;191 

[20] 

:211 

!221 

i231 

:241 

:251 

Page 68 

CERTfFlCATE OF REPORTER 

Elizabeth J. Walker 

Offiaal Reporter 

_- 

_. 

__ 

-_ --~-- 

Page 67 to Page 68 OIC-starr 
1330 

01330 
1331 

Nancy Hernreich, 2/26/98 

Page 1 to Page 38 

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 
1332 

0% Nancy Hemreich, 2126196 

Page 1 

1:; UNITED STATES DISTRICT COURT 

FOR THE DISTRICT OF COLUMBIA 

[‘i________‘-_-___-x 

[3!ln re: 

I~~GRAND JURY PROCEEDINGS : 

16‘ .-, 

,Tl______ ________ -0Y 

I ,:- 

I:; 

Grand Jury Room No. 4 

United States District Court 

I101 for the Drstnct of Columbia 

Ill1 3rd 8 Constiiution, N.W. 

[121 Washington. DC. 20001 

(131 Thursday. Februa 26, 1998 

The testimony of NAN 

I: :i resence of a full 

r8 Y HERNREICH was taken in the 

uorum of Grand Ju 

‘16’ 

&3 98 7 

ptembe&~gi&N WfSENBEf%G 

commencin at 1 ‘yi :12 p.m., before: 

97-2. impaneled on 

l17? 

[la; ROBERT J. BI-fTMAN 

[I91 JACKIE M. BENNEI-T, JR. 

[ZOI DAVID BARGER 

t211 Associate Independent Counsel 

1221 

[231 ~~~~~~~~~~~~~~,‘~~~h~st 

I241 Suite 490 North 

I251 Washington. DC. 20004 

Page 4 

: : : From your testimony yesterda in descnbln the few instances 

;:.that you recall seeing Monica I ewlnsny. IS i?fa,r to say 

: 3 .that rt would have been unlikely that you would have raised 

: 4 the topic with the President as opposed to him raisin it 

:5,with you in terms of, oh, yes, Ms. Lewlnsky is a frien % of 

:E:Walter Kaye? 

(7: A A ain I don’t recall. 

Q O$ay: Is that somethtng you knew or is it 

ii! something the Presrdent told you? In other words when you 

;: c 1 say you had a conversation with the President about the 

: 1 I : fad - or words to the effect that Monica Lewinsk was a 

[ii !frieIId of Walter Kaye. is that something you told t;. rm or he 

r13;told you? 

[14: A That was somethin he told me. 

Q Do you recall whet % er thts conversation occurred at 

/::;a time when Monica Lewinsky was an intern or at a time when 

[ 1: 1 she was no longer an intern and worked for L 

IIS ! Affairs or was it a time after she had Taft the 

islative 

I&e House 

t19lto work at the Penta on? 

1201 A I don 4 recall 

Q 

;:1;21st date did 

Before the story broke. again using that January 

t231about Monica I 

ou have any conversations with anyone else 

ewtnsky or conversations that concerned or 

124 Idiscussed Or referenced Monica Lewinsky? Besides the 

t~]Presrdent in this one incident you related to us. do you 

Page 2 

PROCEEDINGS 

I: i Whereupon 

131 NANCY HERNREICH 

[ 4 1 was called as a witness and, after having been duly sworn by 

r 5 1 the Deputy Foreperson of the Grand Jury, was examrned and 

16 1 testified as follows: 

I71 EXAMINATION 

I81 BY MR. BARGER: 

191 Q Good afternoon. 

[lOI A It is. isn’t it? Good afternoon. 

[Ill Q Thank ou patient1 for waiti Ms. Hemreich, 

[ :Z 1 you are the same Ms. bmreich that testiiyesterday 

[ I 3 I afternoon. correct? 

[14] A Yes, I am. 

[:5‘ Q Thank you for waitin 

: : 6 j move along as rapidly as I can. 

for us. I will by to 

I’d ‘f Ike to cover any 

; : 7 I conversations you did have with the President of the United 

” 0 ;States concernm 

iii:Januaty 21, 1992 

Montca Lewinsky that occurred before 

L-i, You may recall yesterday we talked about the 

i: : : four cate ones of 

recolle c? P 

rivilege that were asserted and, as 

~2: J I, one of hose concerned conversations with the 

:-3.Presdent that occurred after on or about January 21st. so 

; 2 c : my first queshon IS limrted to any conversatrons you had 

1: 5 : before that time period. Were there any conversations? 

Page 3 

::: A I can remember a eneral conversation. 

;: 0 Okay. Can you te iI us, as best you recollect, can 

: 3: you relatef us the contents of the conversatron? 

:: I remember that the Presrdent told me at some point 

: 5; that Montca Lewinsky was a fnend of Walter - from New York, 

::i!hme. 

I.^, a.-. Q 

A 

Do you remember where this conversation occurred? 

113: I thank R occurred in or around the Oval Dffica. 

, I 4 : That’s what I remember. 

il5; Cl Do you remember the context? In other words, do 

; ;;; you remember why the topic came up? 

A 

Q 

No. I don t remember why it came up. 

Would R have been something ou would have raised 

j :i iwith the President or would it have been some zi 

rzrrlwould have rarsed with you? 

mg that he 

1211 A You know, I don’t recall the context. 

12’1 

tz;ithat a 

0 Okay. 

little bit - 

I understand. But if I can just explore 

[241 A Sure. Fine. Absolutely. 

I351 Q Just to see if anything jogs your recollection. 

c 

Page 5 

[I I recall whether you hacl,any conversations with anyone else 

ij;z the~tof)i broke. 

assume that means in the entire - from the 

151 - Q The entire universe. 

A Yes. Whatever. I had a conversation once with 

I,” j Stephen Goodin about Monica Lewinsky. 

181 0 

A 

Anyone else you recollect? 

Possibly others but I can’t say for certain other 

r:zithan that one conversation. I feel like there probably were 

111 lothers, but I can’t recall specficall~. VW know, anv other 

i 12 i conversations. 

i:8: A He had told me that Ms. Lewinsky had attended 

[ : s: another radio address when I was not at attendance at that 

tro;particular radio address. 

Q Ap 

Iii i conversation with RI 

roximately - what was the context of this 

[ 2 3 j topic WrlX3 Up? 

r. Goodin? In other words, why did this 

[24; A I don’t know why Mr. Goodin brought it up with me. 

125: Q I take it. then. it was something he initiated with 

Page 6 

:11you? 

!2: A Yes. He initiated It wrth me. 

13: Q Can you provide an more context? In other words. 

[ 4 ; based on what you’ve said so far, 

1 s?Mr. Goodin just sort of blurted out, 

i!sounds like essentially 

[ 6; Lewins 

‘oh. by the way, Monica 

[?!mere. l ‘r 

was at another radio address and you were not 

mean, can you 

[ 9 !wouM volunteer or bring 8i 

ive us any more context of why he 

IS informatkrn up? 

Well, I can’t really speculate on why Mr. Goodin 

Q 

$$adio address. 

So this would have been at or near the time of tha 

[221 A 

0 

I thought I said that at the beginning. I’m sorry. 

[231 

A 

You may have. 

$:;a white. 

I may not have. I get a lithe dingy every once in 

But it was a radio address when I was not - she 

olc-starr Page1 toPage6 
1333 

___-__ 

Nancy Hemreich. 2126196 

Page 7 

;: 1 attended a radio address when I was not in town. 

:q: ,-. Q 

: 3 1 address. 

And he let you know that she had attended the radio 

!4‘ 

:5i 

A Yes. 

MR. WISENBERG: David? 

(6; MR. BARGER: Yes, sir? 

i’: MR. WlSENBERG: Do 

[El MR. BARGER: K 

ou mind if I butt in? 

Not at a 

191 BY MR. WlSENBERG: 

Q You said that you don’t recall the exact words. 

i:F;Tell us everything you recall about the gist of the 

[ :z J conversation. 

II31 A Well, that’s what I was t 

: 14 1 back and just say I was trying to recall x t

ing -okay. Let me go 

e conversation per 

i I 5 1 se and what else he would have said in the conversation that 

: 16 !would have led me to believe why he was telling me that. - 

ii71 

I 

Pause.) 

do not recall anythi 

j:~jspecltically in that conversation “& 

else that he said 

[;lolfurther clues as to wh 

at would ye me any 

he you know, broug t d all up. 

I211 MR. BARGER: ’ Sol, more? 

:221 MR. WISENBERG: 

!23] BY MR. BARGER: 

Not right now. 

0 Was there something about Ms. Lewinsky’s status 

i::ithat caused Mr. Goodin to bring this to your attention? 

Page 10 

[il Q Okay. You mentioned Mr. Goodin. Let me turn 

I 2 lyour attention to some soetic individuals. I alluded to 

[lSJit? 

[I61 A Yes. 

Q 

IZisort of a reference 

All right. Using again the January Zlst d&e as 

f 191 broke, do you reca R” 

int, do you recall after the sto 

whether - and I believe it migh r have 

[zolb$en a Fnday - that Betty Currie either left work earl or 

r211dldnY come to work? So rt would have been around F. nday the 

[22123n+ I believe. Do you recall that incident where Betty 

r23ldidn t come in on that Fnday or left work early on that 

[24]Friday? 

[251 A Yeqldo. 

Page 8 

111 In other words,, to let you know that Monica Lewinsk had 

:z]attended a radto address while you had not been in r own? 

[ 3 1 In other words, was there some sense that peo le needed to be 

c 4 laware that Ms. Lewinsky was coming into the &hite House? 

[ 5 ]A ain. goin back to, in essence, sort of some context as to 

[ 6]W ii y he wou Id have let you know this. 

I mean, my impression - I mean, it suggests the 

ii i possibility that it was unusual or something that someone 

; 91 needed to be aware of so as to let you know that Ms. Lewinsky 

: 101was here this weekend while you were gone. 

!::I A I think Stephen always tned lo keep me informed 

::2 iabout, you know, the comings and goings of 

p” 

ople and he’s a 

: 13 lvety thorough young man and it’s his nature o do that. 

:14: 0 Fair enough. but would you - you understand my 

: I 5 : perspective, that it suggests that there’s something - 

; E : perhaps unusual is too strong a word, but i! suggests !he 

: 7 1 necessity to keep someone a 

: 5. the White House. the fact tha 

p[rt?ed !ha! Monica Lewlnsky is in 

: j: attention. 

e s bnnging It to your 

.__ 

: i f that 

A 

would 

Well. agaln. I can’t say why he told me. I think 

be somethlng you would have to ask him, number 

‘:: ‘one. Number two. I don’t think it was unusual for him to 

__ - :. tell me that somebody was there or to debrief me on 

.-- . sttuatlons. you know. of anybody who would wme while I was 

.:5:gone 

Page 11 

Q 

I:ito contact Ms. Cume? 

Do you recall whether you did anything to attempt 

131 A I might have. There were periods in that time when 

[4 lshe didn’t come to work that if she hadn’t called me, I 

15 1 have called her. I don’t remember if it was that day or 

might 

[ 6 1 another da And just said, you know, “Just check in with 

171me, let me now what 

[aI 

\ g’re doing.” 

0 Okay. 

A 

- I’m sorry did 

r 

ou finish? 

[ :,‘i know, not 

Yes. 

oin 

“Just if you’re going o be at work or, you 

8% 

to be able to be at work today.’ 

o you recall whether 

i :: i Mrs. Currie on that Friday, the 23rd fy 

ou attempted to or beeped 

o 

A 

January? 

[131 

Q 

I don’t recall if I a ed her that Friday. 

Okay. Has anygdy at the Whiie House shown you or 

I:ljlet you review various telephone records? 

:::;rewrds. 

A I don’t t&i&e I have reviewed any telephone 

1181 Q Okay. Do 

[lglaround that time period a x 

ou recall whether you paged Ms. Cunie 

[201 A 

er the story had broken? 

[21]in that time. 

I paged her at least once and maybe more than once 

Q 

Iz:iyou paged her? 

Do you recall the message that you sent her when 

1241 A 

[251WU#. 

I think I had told her to call me as soon as she 

Page 9 

BY MR. WISENBERG: 

Q 

i_.more than one 

Typically. aren’t there a lot of people. certainly 

erson, who witnessed these radio addresses? 

.;‘ A !es. 

.: BY MR BARGER: 

Q Did he grve you a list of who else had shown up 

.r:wh~le you were gone? Or was Ms. Lewinsky the only one he 

: F .singled out3 

i A I would have liad that most likely in my briefing 

i ? ‘notes, so I could have reviewed that. 

;:1. Q 

1: : bnefing notes7 

Would you have also had Ms. Lewinsky in your 

“:- .-2. A I don’t recall. 

{:5:there. 

(2,:’ 

!^.: A He let me know. 

<--. 0 For whatever reason. I.-,. 

.-- A I don’t know if singling out is a good enough word 

f: 3 1 and he ma 

:: 4 1 that were t E 

have told me about a half a dozen other people 

ere that day that he brou ht to my attention. So 

; 2 5: singling out is not a word that I wou k? necessarily say. 

Page 12 

(11 BY MR. WlSENBERG: 

I21 0 Ms. Hemreich. would that have been a page that you 

[ 3 I sent pr a messa 

14 1 morning where rs1 

e that you sent relatively soon after the 

s. Cur+ came in early, left and left a 

151 message that she was going to be talking with her attorney? 

[Cl A I don’t recall. 

ii;hef? 

Q Do you recall who, ti anybody, asked you to page 

191 A 

0 

I don’t recall that anybody asked me to page her. 

:::;a~ possible? 

Do you recall why you wanted to talk to her as soon 

A 

/::ias possible. 

I don’t recall why I wanted to talk to her as soon 

i141 MR. WISENBERG: 

rzltopic. 

That’s all I have right now on that 

I161 BY MR. BARGER: 

0 

1 :i i me ASAP do 

Assume that the pager message basically said call 

ou 

r. 

recall whether there was any other incident 

rlslon that Friday rrne period that would have occupied 

rzolattention 

our 

besides the Monica Lewins 

[21 ]yords. by process of elimination is It 

o&er 

Mn Currie in rdlali%~?~~o!i 

1%~11%n% K%% 

ir to sa that 

.~. , 

I241 

I251 

_ A No, I woukl not say it was likely. 

Q Andwhy not? 

Page 7 to Page 12 olcstarr 
1334 

BSA Nancy Hemreich, 2126198 XMAX(V 

Page 13 

.1. A Well. I think - she was out and there could have 

; s j been, I think, a dozen thmgs or a hundred things that I may 

'3: have needed to find out about that she would know that I 

: 4 ! wouldn’t know that I would have to call her about or need to 

f s 1 talk to her about. 

:6: 0 I understand there could be. obviously given the 

: 7 1 positions you and she held, literally hundreds and 

i 3 1 more possibilities. but 

perha s 

ou understand the context IS tha 

b 

P 

! sIthis message came to er from you shortly after she left the 

.: 3 j White House and left messages that she was going to meet with 

:: I 1 her lawyers, after the story had broken, okay? 

; :z 1 understand that? 

Do you 

"31 A Okay. Well, you’re making an assumption that she 

i i4 1 had left me that rrtessa 

::slthatday. Ijust-Idon $ 

e and I’m not positive of that for 

recallifshehadteftmea 

;6 1 message that da 

: : 7 ; coming in early. Y 

and you had said something also about her 

don’t recall that she had come rn early 

: 19 tar left me messa es or notes or anything. 

:I31 BY MF? WISENBERG: 

Q You don’t recall if the day on which you paged her 

i:i;and said something to the effect of call me as soon as 

~221 ssible was the same day that she came in and left a message 

;23] p” hat she was talkin to her attome ? 

A No 9 don’t recall d was the day she had left a 

iflimessage to that e’ffect. 

-K 

Page 16 

[ : 1 concern about somebody’s well being, not so much her 

12 1 whereabouts as her well being. 

!3j Q In the same vern as the 

[I 1 being telecommuntcahons. my segue. 8 

aging toprc. the same vein 

o you recall ever having 

[ 5 1 any conversations with Vernon Jordan about the Monica 

[ 6 1 Lewinsky matte0 

A I don’t recall ever having any conversations with 

ii ;Vemon Jordan about the Monica Lewinsk matter. 

Q Okay. In general, did you H ave conversations with 

r:i;Mr. Jordan - I guess let me back up. Were there occasions 

111 Iwhen Mr. Jordan would call the President? 

A Yes There were occasions when Mr. Jordan would 

~::~call the President. 

Q And on some of these occasions, would you put 

1::; Mr. Jordan through to the President? Would ou be the 

[~sjfacilitator or the intermediary? I don’t know w r; 

[17]wofdwoukl be. 

at the rght 

[ISI . A 

Cl 

Yes There would be occasions I’d put him through. 

All ht. On those occasions, woutd you talk to 

[:ziMr. Jordan or wou Zy just simply; 

[zl jget the President? don’t know w 

“Hello,. Mr. Jordan, 1’11 

at the right procedure 

[22115. but would you have occasion to talk to Mr. Jordan about 

tn3lanything substantive ? 

[241 A What ‘a o you mean by substantively? 

1251 Q Well. what I’m getting at is if Mr. Jordan caked 

Page 14 

BY MR. BARGER: 

ou confident in your recollection that no one 

1.3; A 

Q 

I don’t recall that anybody had done that. 

.li’ Would that have been the kind of thing you would 

: : 5: recall, if someone had done that? I mean, in other words, 

: : 6; are you farrly confident that no one did? 

.._. A Well, again, there were quite a few days that she 

.I? ) was out. There were periods of time that I didn’t know what 

: 5; she was doing or I hadn’t received a direct message from her 

.: T I and I would have - you know, so I can’t tell you, you know, 

::: : if it was a day that somebody - you know, even somebod in 

.::!the office ma 

.:j.sure if It was Y 

have said something to me, but I can’t say 7 or 

hat day or if anybody ever said anything. 

.;: ;There were four or five days In a row, I think, she was out 

‘15 1 at least, maybe longer. 

Page 17 

tllthe President, perhaps they had a conversation, but it is 

tzlpossibte that rf he is calling the President through you, 

t31perhaps ou had a conversation with Mr. Jordan as well and 

[ 4 ISO that’s r he part of it I’m asking about. Dii 

. 

[ 5 1 conversations with Mr. Jordan when he wou lb 

ou have any 

call the 

[ 6 I President? 

A Yes I would have conversations with Mr. Jordan 

ii;when he would calithe President. 

0 Dii any of those conversations with Mr. Jordan 

I :z; relate in any wa 

A 

to the Monica Lewinsky matter? 

f!o. I don’t recall any conversations with Vernon 

1::; Jordan regardin the Monica Lewinsky matter. 

1131 Q 8r the Paula Jones lawsuit matter. 

II41 A I don’t recall any conversations with Vernon Jordan 

[I 5 1 regarding the Paub Jones lawsuit matter. 

[ 19 1 Mr. Jordan calling the 

jzolperiod? 

A Yes, I do recall Mr. Jordan calling the President 

i gi; in that twemonth period. 

Q Do you have an 

I zii many times Mr. Jordan called t fI 

recollection of approximately how 

e President during that 

[ 2 5 Itwomonth period of which you would have knowledge, meaning 

Page 15 

Q And that four or five days in a row, this is the 

i j time period after the story broke. right after the story 

3. broke, right? 

‘I‘ A That’s ri ht. 

:. Q Just to P allow up on our answer was there anyone 

i :who suggested any concern over &. Curries absence? 

-7Besrdes yourself. And I’m not su 

: ~conc-ern. but was there anyone w 4 

gesting you expressed some 

o expressed any concern about 

;!Mrs Cume berng gone dunng this time period right after 

: 1 I 1 the incident became public? 

: 1: A 

: : : ; personally. 

I think there was certainly concern for Betty 

--,i: .--: 0 

A 

And who expressed that concern? 

Well I think most of her friends in the White 

i i z i House expressed cbncem for her personally. 

Q Did those friends in the White House expressing 

( i z jconcern include the President? 

::?I A I don’t recall if he said anything to me 

: : s 1 specifcally alon those lines. 

:Z?: Q &en you sai “specifrcall~ alon~;;~.i~,” and, 

: 2 : 1 again, I want to try to cover t e universe ere. 

::2 lgeneral express concern for Ms. Currie’s well being or her 

: : 3 ! whereabouts, given the fact that she was gone for a number of 

:; 4 : days right after this sto broke? ,_I_. .-31 A It would% In the Presidents nature to express 

Page 18 

11 jsomehow you’re helping place the call or putting him through 

I z 1 or whatever? 

l3i A 

Q 

I remember two phone callsz 

1 :iconvenation with Mr. Jordan? 

In any of those instances, drd you have any 

~::~thereweretimeshem’ htdoit. 

Q Okay. % best you recollect generally the times 

i ::; when Mr. Jordan dii let you know the purpose or the nature of 

t 161the phone call, what were those 

A Wen. I’d say that 

i:li but it would alwa 

R, 

urposes? 

would say the pu 

4z 

rFseoft* 

1191 nature to be a lrtt 

be somewhat vague. It would ba emon’s 

Q 

obtuse about it and not be specihc. 

Okay. In light of your earlier answers though, 

I:iias best you recollect whatever urposes he ave you they 

122 ~did not relate to Monica Lewins ! y or the Pau % Jones jawsuit 

t23tmatter. Is that fair to say? 

1241 A That’s fair to say. You’re asking me if these 

t251conversations related to that and I had earlier said they did . 

_~ --__ 

OlCStarr Page 13 to Page 18 
1335 

BSA Nancy Hemreich, 2126198 

Page 19 

;: ! not, at least that I could tell. 

II, Q Okay. Yesterda 

i; i background with you in terms o IV 

I did a very brief bit of 

your coming to work for the 

!4 ~President. You basicalty started workrn for the President 

(5 1 when he ys governor In about 1985, I &eve, correct? 

/76; Q 

In a pard posrbon. yes. 

Now when you say in a 

t 8 j some volunteer work earlier for Mr. Clin P 

aid position, had you done 

on? 

131 A Yes, I had. 

1101 Q That was in the nature of assisting on campaigns? 

ill1 A That’s correct. 

Q And that was not uncommon, for you to assist in 

i::ivarious campaign efforts for different candidates, is that 

ri4lfair to sav? iis; ,A 

Q 

That’s fair to say. 

Okay. Is that how 

I :: igovemofs office for employment t 

ou came to the attention of the 

!I ere, 

i I 8 1 volunteer work? 

through your campaign 

I191 A 

Q 

Well, 

All rig 5: 

ossibty. In part. I think. 

1. When you came to work for the governor. 

i$y;as I understand it. basically you had a friend who was 

[ 22 1 bavin 

[ 23 J you? 9 

the position ou ended up taking over and she called 

s that genera r ly - 

[241 A 

Q 

No, say that again. 

1251 Let me back up. As I understand it - strike what 

Page 20 

1 I 1 I understand. Dii you have a friend that worked for Governor 

t: 1 Clinton byihe nae;e of, I believe, Carol Rascoe? 

I31 

Q And Carol was teavin 

/:; see if vou were interested in takina t 4 .. 

a position and called you to 

e oosrbon as 

I 15: attentron throuah - 

ht have to ask her this, but 

: : 6 : other work I wa’s doing. 

..- Q And you have worked for the President either as 

1 i: j governor or as president for about the last 13 years, 12, 13 

: :: years.7 

.--. A In a paid osition. 

.-. 

_. 0 ? I’m sorry. .^_. 

.-- A 

Q 

There was a lot of work in unpaid 

As I recollect it, you and 

:! 1 ,done volunteer campaign work In the ‘7 

-L : pald posrtlon. 

before you got your 

_ 

Page 21 

ht. 

: Presdent. 

e 13 years that you have worked for the 

you characterize your dealings with him? 

In other words, fnends. close friends. stnctly business 

_ assoctates or colleagues? I mean, how would you perceive 

i your dcalrlgs wrth him? 

: related 

I percecve m 

I feel like we proba r;r? B 

dealin s with him rimarily business 

: i perceive our relattonshi 

ly sta ed as friin s. but I 

..- 0 During t t! 

as a business relationshi 

e time you have worked a P the White House, 

: I f did you ever hear any rumors or suggestions that the 

1: I Presrdent had a possible romantic invot,vement.or a romantic 

! : 3 Interest or~uramlationshtp wtth Monrca Lewrnsky? 

i:;: i 

..-. 0 When those allegations became public, were you 

: ; e : surprised by those allegations? 

[:ii A Yes. I was. 

“?I L--. 

[i?: If;“l”& R WI ENBERG: 

f z t 1 minutes. 

We’re going to go five more 

ifi ia 

MR. BARGER: 

second? 

Could I have your indulgence for just 

1-3: 

[Z41 @$%GER: 

[ 25; has a few questions. 

I have nothing else, but Mr. Wtsenberg 

Page 22 

THE WITNESS: Okay. 

BY MR. WISENBERG: 

i3: Q Ms. Hemreich. I want to go back briefly to the 

c 4 1 report you got from Mr. Goodin about Ms. Lewinsky in relation 

! 5 1 to the radio address. 

11 I1 he witnessed Ms. Currie escort Ms. Lewinsk into the Oval 

~12~Office? Do you remember him reporting tha r 

[ 13 I that to you? 

or anything like 

(141 A No, I don’t remember him reportin that. 

[151 0 Did f% 

1161 A No, Y 

ou hear something like that m anybody? 

Q 

didn’t hear that from anybody. 

You said you didn’t hear any rumors of a. 

i:i{relationship prior to this becoming a nationwide story. 

tls]You heard no rumors of a relationship 

tzolsexual between Ms. Lewinsky and the 

, prspnal. social. 

[2llWrrect? 

resident, ts that 

I221 A That’s correct. 

Q Were there rumors about Ms. Lewins being what’s 

I::;calted a clutch? Had you heard an rumors about tha dunn 

tI 

kJ .. 

rzsjetther her time working the White ouse or in the Pentagon 9 

Page 23 

rl~doyouknowwhatlmeanA I know what 

::ithink about that and think if r hats - if I can honestly 

ou mean’by a dutch and I’m trying to 

11 Ianswer yes to that. That’s what I’m thinking about. I think 

[ 5 1 the answer would be yes. 

I61 Q 

A 

Do you know who you heard those rumors from? 

The person that I can remember thinking that or 

Ili having a sense of that was Evelyn Lieberman. 

191 Q Do 

I lo~wnvenation, she x 

ou remember any conversation, me gist of any 

A 

ad wtth you about that topic? 

! :: lshe had with me about it. 

No I don’t remember the gist of any wnversation 

il3i Q 

A 

And what is your definition of a clutch? 

Well, I’m not sure. That’s why I had to spend soma 

~::]ltime thinking about that, what my definition of a dutch 

[ 16 lwould be or whether I would say that. I think it would have 

[ 17 1 been more Evelyn’s definition and it was a sense that maybe 

( ISI! think Evelyn thought that she was around too much or - I 

t zoliittle flirtatious. 

[ 191 ust think that’s generally what she - that she was maybe a 

I think that’s Evelyn - I think again you would 

I :i 1 have to ask Evelyn what she thought but Evelyn had a general 

[23]sense that she was around too much: I think. 

Q Okay. That Monica Lewinsky was around the West 

1 i:; Wing and Oval Office too much, is that a fair statement? 

Page 24 

A I think the statement would be not that - I don’t 

I: &eliive that is a fair statement that’s my answer. 

131 0 

A 

Around the West Wing too much? 

Possibl 

I:;what she though abou r 

But I think you’d have to ask Evetyn 

that because I did not have a long 

c6lwnvenation with her, but I just had the sense she fett mat 

t71or thought that so-we’re into areas that-you know, I 

rsldon’t want to characterize what Evelyn thought or fett about 

[ 9 I It. 

[lOI Q I don’t want 

I 11 Ithat YOU qot an impression i: 

ou to, either, except to the extent 

j I I j Liibem$n told ou. 

ased won somethino _ Evetvn e 

[131 A Jut you’re 

I II I I - I’m sorrv. I iust car0 te 

etting very specific about things mat 

ilsi a‘ 

R vou. 

‘And what is fi that you remember. to the best of 

t161your recollection. about what Evelyn Lieberman conveyed to 

117 1you about her concerns regarding Monica Lewirtsky? 

A I don’t think Eve 

i :i; anything or at least she certain ‘r; 

n specifically conveyed 

didn’t verbally or an 

tzoltong seniences, I just had a sense that Evetyn didn’t l&e 

[ZI 1 her, didn’t - for some reason or another. 

Q And somehow that was related to her being 

[::;flirtatious and hanging around too much. 

1241 A Again, I think ou real1 woutd have to ask Evelyn 

rzslthat because I got the sense % velyn J tdn’t like her and 

Page 19 to Page 24 OIC-starr 
RSA .____ 

1336 

Nancy Hemreich, 2/26/98 XUAX(S) 

Page 25 Page 28 

;: Twithout havrng long specific or an 

K 

conversations that I can 

;z.recall wrth Evelvn apout it then - ut. vou know. it could 

rj:have just been faual expressions. I don’t knowwhat. I 

I 4 :just had the sense Eve1 

Y 

n ddnY like her. 

[5: 0 ou had mentioned the word flirtatious, 

I 6 1 though. 

Okay. 

1:: A, 

! s!some 

[8 i but, ;#ln 

Well. that, was the sense that I got from Evelyn, 

rng that Evetyn - you know this would have to come 

I m ~racterutng - I hate to characterue, 

[ lo:Evel n. her feekng about R. I did not have those feelrngs 

[ 111 and ere I am trying to characterize what Evelyn felt or 

rlzlthought. 

I131 Q But you got that sense. 

I14: A 

rls!her. 

I got the sense from Evelyn that she did not like 

Q Aa gatekeeper, you described your role as 

1:76igatekeeper. given what you do, officially and unoffiually 

[is jgiven your &described robs as gatekeeper, would a clutch, 

1191a person who I’ve described aa a clutch, have a reason to 

rzolavoid vou? 

i21j - A I don? know whether the would or not. 

Q In other words let’s say !h at I am a person who 

IZ;wants face time wtth the P&dent. Let’s sa I’m a person 

124 Ithat wants face time with the President. I’m r rymg to 

[~slfigure out how I can get around the President. Based on your 

111 the nature of the phone call, the purpose of the phone call7 

12 ~“Can you get Mr. Jordan on the hne. I want to talk to him 

I j I about X.” Can you tell us basically what the Presrdent told 

[4!you to do? 

A He did not indicate what he wanted to talk to 

~~~Mr. .~. Jordan about. 

Q Can 

Ii 1 he say? Jrt GE:. rx 

ou just sort of give us the gist? What WOUM 

r. Jordan on the line”? 

I91 

[lOI 0 Or words to that effect? 

[Ill A Yes. “Get Vernon on the phone for me.” 

I121 Q Did he 

[131subjeU matterwas? 3 

ive you any indication at all what the 

A 

e berng the President. 

;::;to the subject. 

MO. he did not give me any indication whatsoever as 

0 And I guess last .ust to follow u on Mr. 

i :t iwrsenberg, if a clutch wanted td ire P 

[la110 avoid you? 

smart, wou d they attempt 

A You’re asking me a uestion that I can’t answer. 

~:~~I mean, you’d have to ask a clutch t % at rather than me. 

tzsjwhen they’re 

Page 26 

I 11 knowledge of what you do 

[ 2 1 get around the President &f$&~~~~~/h~~ t&\71Fit be 

[ 3 1 easier for me to try to get face time with the President when 

[ 4 1 Ms. Hemreich was not at her desk? 

A I donY know. That’s hard for me to sa because if 

i zj I’m not there and can? observe that then I can’t tell i? 

[ 7 1 that’s easrer for someone to do when I’m not there or not. 

[a 1 Ican’t tell ou that. 

19; & Well, assuming that it would be easier if you 

1 lolweren’t there, what would our answer be? 

::I: A Assumino x at - now. start all over. Assumino 

i !: j don’t have a good reasorito-be there. are you going to do 

( 15 :somethrng about it? 

I:‘: A Not alwa s. 

“9’ ,A-. MR. WISENBERG: Shall we break for lunch? 

“G 

..- MR. BARGER: 

: z: :questions haven 

Can I just follow up? Just two more 

to do wrth the Vernon Jordan topic. 

._. ,-A. BY M%. BARGER: .^^. 

,-- Q Did you know anything about or had you heard. did 

:: 3 :you. have any understanding about any efforts by Mr. Jordan to 

: I 4 : assist Monrca Lewmsky in locahng employment or getting a 

;rs;job? 

Page 27 

. A WouM you ask me that again? I just want to make 

: I ‘sure that I was - 

13 0 Sure Did you know of any efforts by Mr. Jordan to 

I : ‘asstst Monrca Lewrnsky in locating employment or getting a 

j 5 ,job7 

$6 A No. I did not know of any efforts. 

:- Q And when I say know. let me broader. Did you 

1s have an understanchng, had you heard, were 

! ;:that km d 

ou aware of, 

of thing, beyond just, for example, tal I!. rng to 

1: 2 ‘Mr. Jordan direct1 

[ : : ‘sources that Mr. .K* 

had you heard any information from any 

ordan was attempting to assist Monica 

: : 2 : Lewinsky In locatin 

A 

a job? 

1 i: IMr. Jordan helprn 

No. 9 don’t - I had no knowledge of any sort about 

9 

Monica Lewinsky get a job. Does that 

: I 5 ianswer your ques eon? 

1161 Q Yes. And last. goin 

[ : 7 ! when I asked you about calh from, a 

back to the telephone calts. 

1 i9 ! the other half of the 

r. Jordan, I d;kfn’t ask 

1 I ?!period. December ‘97 hro 

Tab;. Dunng tr;lat same trme 

~~o:calls to Mr. Jordan on beha 

h January 98. did you place any 

of the President? 

[:!I A Yes. Idid. 

iii i for the Pre$de%$o~ period. 

proximatep how many do you recall doing 

Gwe us a range. 

(241 

c15; Q Okay. Did the President indicate generally to you 

Page 29 

[ 1 ]a judgment about something I’m observing behavior. 

[21 MR. BARGER: Gkay., 

[31 

%i?$~~%~~d?ni%~iere any questions before 

I l; I give an admonition? 

Let me ask 

/76jfew moments and we’ K come et you. 

ou if you could step outside for just a 

IBI THE WITNESS: akay. 

I91 

I101 

ppeles~ex~l~R~~ness rewlled.) 

Page 30 

(11 A I don’t think I thought of her ve 

[: I or!e way or the other. And jet me just say to 2 Fu* at alL 

(3 l think clutch is wa too strong a word. 

anfy, I 

141 Q Okay. Did you, based upon your viewing of her and 

I 5 1 things you heard about her, have the im ression that she was 

t6]somebody who hung around the West \R tng too often? 

fi;so I wouM 

A I didn’t see her ve 

not say that I thought s x

much in the West Wang at all, 

e hung around the West 

ts]Wing too often. I just never saw her there. 

I101 Q The question was based both on what you saw and 

[ 11 what you heard, did you have an impression of her as somebody 

[I? pvho hung around the West Wing too often? 

I131 A 

0 

No, I didn’t. 

1 ::{did about whether or not you had heard any rumon’before 

Okay. I asked you a question earlier or somebody 

/ [I 6 ] thi became a public matter about a personal sexual 

[I 7 1 romanbc relationship between Ms. Lewinsky and the President 

tlejand 

t19jsligh!jy different question now. 

our answer was that you had not. I’m going to ask you a 

Based upon any incidents that 

i:i;heard about. incidents that you witness erK 

ou witnessed or 

or heard about, tii 

[zzjyou ccme to a feeling or conclusion that there ma 

~23; 

I? P 

ssibb, a rsonal. social,or sexual relationship %le 

have been, 

tween 

124 1 

t2s1 

s. Lewrni y aN;.the President? 

0lcstalT Page 25 to Page 36 
1337 

By Nancy Hemreich. 2/26198 

- -. 

XuAXfCl 

Page 31 

;1: Q Is R the policy. you’re part of the Executive 

i 2 1 Qffi~e of the Presldeflt. to only gage people or call people 

: 3 1 at home fok matt5-s of urgency. 

l4! 

!51 tf you were a clutch, would you try to avoid you? 

16; 

2 

171 Q %%%% physically impossible - 

IBI A Oh. that’s funny. 

191 MR. BARGER: A metaphysical question. 

1101 BY MR. WISENBERG: 

111! Q 

[ I z I somebody like 

If you were a clutch, would you try to avoid 

ou? 

!13! A 8 I was a clutch, would I avoid somebody like me? 

i I 4 IWell, part of me wants to say I hope not. I don’t know, 

1151 honestly. You know that’s a difficult question for me to 

[16]anSwer and I ho 

Q 

i:&etty Curne? 

\Rewld you chara erue yourself as tougher than 

l’m not that %htenrng. 

1191 A 

itoiBetty cunie. Yes. I would characterize mvself as towher then 

1211 Q If there were people where they shouldn’t be. for 

rtz~instance. in the White House. would it be fair to sav - 

i23jincluding the area around Betty Cunie’s desk and your desk. 

1241 I take it you would ba more likely than Betty Currie to tell 

[25jthem t0 get lost? 

Page 32 

[II A Yes. mats correct. 

Q 

I$ j spending time around 

Okay. How o2;gF you witness Ms. Lewinsky 

Ba 

A You know, tt? don’t recall any incidences of her 

I:; hanging around Betty Currie. 

I61 0 Okay. Or with - I uess hanging around is kind of 

17 ia loose word. In the presence of 8e ttv Cunie. 

::: jperson the are 

::3‘ d Okay. Are you saying that you would not 

~24~necessarily right than go up and sa 

.:51you might speak to them later abou r. 

Leave thus area,” that 

d? 

_____.~__ _ 

Page 33 

.A. A No. that’s not what I’m saying at all. 

.9. 

,- Q Okay Tell us- 

:3’ A Well. I may not say anything. 1 think if the 

: P ; person IS somebody who - I mean, you have to make a jud 

: 5 i about those things and rf they’re somebod 

’ 

ment 

; t vwould look at what’s gorng on with them, 

who’s havtng - 

i&s somebody 

: - ‘who’s having maybe a hard time or somebody who’s insecure or 

I J ! somebody - you know. I reaky wouldn’t want to scare 

f : 1 somebody, I wouldn’t want to Intimidate somebody In some way 

: i O: that would cause them to feel badly about themselves, and so 

1: : 1 Itry to look at the person. If they’re not causing any harm 

; :I lat all. I mean, then I don’t see anv point In doina it. If 

;:3:they’re not. 

. . _ ~. 

!?4’ 0 Okay. So 

i i 5 i that hang around the Ova fy 

ou might continue to kt a person like 

Office area, even if they didn’t 

1 i6 1 have a reason to be there and they had a reputation as a 

, ,_ I 7 /clutch’, j. -.- 

[18i A Possibly Yes. 

1191 0’ 

!2olthat? 

Any other reason you might continue to let them do 

12:: A 

[ 2: ~day. there’s 

I’m sure there are probably - you know, in each 

probab 

; t: 1 jx$bably doesn t be !i% 

- you know. somebody who comes by that 

ng there at least and, you know, rt’s 

- there are all krnds of reasons every day that I 

i_5lwouldn’t push somebody out of there. 

Page 34 

I:: 0 Any other that you can think of, An 

[z 1 particular reasons you can think of that you wouidn i 

other 

have a 

I 3 1 person like that leave the area? 

A Well. I wouldn’t have somebody kave that area rf 

I:; there wasn’t a thousand other people in there. I mean if 

I 6ltttere wasn’t anvbodv elsa in there that thev were d&$b~ng 

[ 7 1 or there wasn’t a huge meetrng gotng on oi people werent 

[ 8 walking back and forth tryrng to go between the Cabinet Room 

Island .~. the Oval Office. 

r101 I mean, there are all kinds of reasons. If they’re 

[ 111 not causing any harm, they’re not creatin a disturbance or 

entiai 

:::1g tr 

craating a disturbance. then rf .9 

the 

hey were in 

re an 

[ 14 I to erther Step K 

want to talk to Betty or if they want to talk 

en 

rlslto get a 

or Chns. the two aides. or they’re coming 

,1,,ESpeaa~~~~~;~~~~~~Yo~~~~~~’ 

[I 7 J and a lot, of people come in and talk to her all, the time. 

; ; ; ~~~~~~~~~~k~~~~~~~~~~~~~~ ,;“-““s 

Q Any reasons you can think of other than the ones 

~:~&u’ve articulated. why you would kt a per&n like that stay 

[22lln the area? 

A Thanproba 

~::~something I really have spe 2 

are but you know it’s not 

a lot of ii thinkin’ about. 

[ 25 ] 1 make dF&ionS daily, lots of decisions daily, a 9 I make 

-ge= 

I; leach one of them 

0 Bt&e there anv other reasons vou can think about 

rsonally and hopefully they’re tight. 

r31nght now? 

I41 A That I would not have somebody leave? 

[51 Q Right. 

161 A I can’t think of any. but, again, there are 

17 1 probably hundreds of them. 

Q 

Honestly. 

I believe you answered this yesterday but in case 

r~o~&sident? 

Ii; ou haven’t. did you ever sea Monica Lewinsky alone’ with the 

~::~President. 

A I have never seen Monica Lewinsky alone with the 

1201 A I think I would recall it if I had seen it. 

I211 0 

[z:lLewinsk 

All right. Have you ever heard that Monica 

[r3lthem In r hat room? 

was in a room with the President and nobody else was 

[241 A 

1251was alone 

No, I’ve, never heard of a time that Monica Lewinsky 

In a room wdh the President with nobody else 

__- 

Page 36 

[llmere. 

jijz~ the President was or where you thought the 

Q HaveyoueverseenMonicaLewins$kavearoom 

resrdent 

, . , _ - __ . 

A 

i z i of the radio address and the Presrdent was still in the&. I 

Well, she left the room the Oval Office the day 

17jbeliave. 

[El Q 

I91 A 

There were others in there, too. 

As I recall. 

1101 Q Okay. Have you ever seen her kave a mom whem 

I 1 I lyou thought the President was and nobody eke was them? 

A 

i :$! I thought the President was there and nobod 

Have I ever seen Monica Lewinsky kave a room that 

I 14 1 I’d have to say that I woulcl - the answer to t 

else was them? 

x at mght be 

. 

[ 15 1 yes and there s kind of a fine diierence between mat and 

I 16 lsome of the other ways you’ve asked the question. 

(171 Q 

A 

Okay. Tell us about that. 

i : : i don’t always see the President at all times whether he’s 

Well, I don’t know - k’s hard to know because you 

12OJalOne or not and there are other ways to get into all areas 

[zllof the White House or into the Oval Oftice ama. But I think 

r22jthe n’ ht that she brou 

[23]to the 5 resident but I B 

ht us food, I kt her take some food 

on’t know for sum if they warn alone 

124 nor not and sha wasn’t in them but about two minutes or three 

(25lminutes, mat I recall. 

Page 31 to Page 36 01c*tan 
I 

BSA 

:i: 

i’: 2 

!3!area. 

!4: Q 

r5:dining room? 

16: A 

I 7 I room. 

Nancy Hemreich. 2126198 _ 

Page 37 

That was the Oval Office? 

I don’t know if it was - it was in the Oval Office 

Okay. Could it have been in the study or the 

It could have been either the study or the dining 

I@1 

I91 

1101 : 

You’re not sure which? 

No, I’m not sure which. 

All right. And you saw her leave. at some point 

i I 1 j leave the are; a? 

1121 A As I recall, it was just a few minutes and Betty 

I : 3 1 and I were on the outside and she offered and I let her go 

I I 4 I back and take the food. 

ilSj Q 

A 

How many is a few? 

i:tithree, four. 

A few minutes? My recoltection, it was two or 

MR. WlSENBERG: Shall we break for lunch? I 

I:i;thought that I could finish before then, but I don’t think 

r20) I’m going to be able to. Shall we break for lunch? 

1211 THE DEPUTY FOREPERSON: Yes. 

[221 MR. WISENBERG: When should we tell the witness to 

1338 

t23)retum? 

t241 THE DEPUTY FOREPERSON: 2:15. 

I251 MR. WISENBERG: Okay. May the witness be excused? 

Page 38 

Ill THE DEPUTY FOREPERSON: Yes. 

I:; 

THE WITNESS: 2:15 did ou sa ? 

THE DEPUTY FOREPERS&: {es. 

141 THE WITNESS: Okay. 

I51 

& 

he wetness was excused? 

hereupon at 1:lO p.m. he taken of 

i; 1 in the presence of a fuil quorum of the Grand 

9 

f B 1 concluded.) 

ury 

I91 

. ..I. 

1101 

Ill1 

112: 

1131 

I:41 

Ii5; 

116 

::-': 

I:?: 

testimony 

1 was 

X~XVI 

Page 37 to Page 38 
1339 

Um.lG-P,CW lm March 26_ 1998 lllcy” 1 VW ------ --,-- - - 

Page 3 

UnIttD SIATLS DISTnlcT counz 

m *HE DISTRICT or WLUIQIA 1 Q And that is what? 

___-___--_-------~ 2 A I’m Deputy Assistant to the Ikkient and D&to: 

UNIM STA?ts OF NaRxcA 3 of oval Office opentions. 

“. 4 Q Sometimes known as the gatekeeper. 

GlulDJvU ?mDcssnIYcs 5 A-,yts. 

________________~ 6 Q In a non-pejorative way. 

orrnaJurynMnr0. 3 7 A Yes. ullltd *UC,. D1SttlCf con?ct 

ter uu ni*crbs. er cdpbia 8 3rd ‘ conw.ir.wion. W.Y. Q You’ve ma& two prior appearances bcforc this grand 

Ialill9fPD, D.C. 20001 9 jlPY,Ibclieve,on~~25thandthenagainonFebruary 

mane*ay, mrch 26. II99 IO 26th In the C&SC of thocx appearances, you wur 

nn CIw.lmany01UlCl -1alrumkul~~ 11 &tnxtaibycounszltoinvoAuaztainpri~comct? 

p,zo- or . loll cpor'a of Orvd Jury 97-2. wld am 12 A&Tcct. 

lurch 29, 1997, commuin9 .t 2:29 p.m., myON: 13 Q h~hahaviagtO~Withexecuti~privilege 

DWID m 

la- XIUICI: 14 for cutain cone and attcnxy-clicnt privilege with 

YIWDY IIscJisnc MIoclaU I~n4.rlC cowl-1 1s regard to other conversations. 

Oftla 0t xM.FMtirt cwn9*1 

1001 knmylvania AVWIW, W.Y. 16 A That’sCOmct. 

suiu 490 ll0rt.h 

WashiaqtDta, D.C. 20004 17 Q AU right. As you understand it today, have you 

18 brminstructitoinvokcprivil~withngardtoanyoftbe 

19 amvasations that you had ball ilzMlcd to invoke 

20 plivilcgeollptiously,ororyounowfrcctoanswer 

21 questions about those conversations? 

22 A IamnOwfrcetO answer qlle!stioIls abOut tbo!x 

23 amvcrsations. 

24 Q Andjustasarefxhrforthegrandjury,canyou 

25 dcllusalittlcbitabout~itwasand~your 

PW4 1 PROCEEDINDS 

1 understandiQgoftkcircumstaocts waStiStledyoUtObC 

Iwhsrupoq 2 told to invoke privilege and now you’re not invoking 3 NANcrB 

4 wac&duawiQlm~~bmlf~~~-~ 

3 privilege? Inotbawords,telluswbyitwasyouinvoked 

s ttleFaqmlaofIbccryldhny,wr~dLclbilsd 

4 privikgc previously. 

5 A So I should tell you why 1 invoked privilege 

6 rrfdbwr: 

6 cdicr. ?btcircrmrstanas~~~~ledUp~ 

7 ExAmNAnoN 

8 BYMR_BARGEk 

7 it? Isthat*you’rtasking? 

8 

9 Q-a 

A Right Imcan,incssen~,youwtretoldtoinvoh 

LO AGod_ 9 privilcgc and couldu’t answu certainqutstionsbccauscyou 

10 were told to. 

11 Q Yaumnydme.Ik~b~id~ 

11 A hhdXnm. 

12 A Idodupu. 

I3 Q H-&=W 

12 Q And now you’re not told to. So can you tell us why 

14 A I'mf-.lbdyou 

13 itwasyouwcretoldto,andthtnwe’llgctto~itis 

IS Q Iqpocirpueocjqbmk Iknarpvhrrcb 14 you’re allowed to. 

I6 -bm&,bucrd~y’nu~bdL 15 A Oh Well,Iwastoldtoonadvictofmycoamscl 

17 AWpu. 

16 dondviccofWhi~Housccounsd. AndthmIantddnot 

18 Q It’~km~wWeshceuahst~,oI’drlr 17 toonthcadviceofmycounsel. 

19 youtDkk&tyyaalAffattlelcomladfatbe~ 18 Q Okay. And your counsel is Jerry Trainor, correct 

20 0fQgraad jmy. 19 A Yes, and Judy Wheat, too. 

!I A MymnneLNmxyHamich 20 Q And your undeaanding of tk White House counsl 

!2 Q Aad,hkiknmish,yaur.olpbyedIrtbcwhik 21 who had previously kstmckd Mr. Trainor to invoke privilcg 

!3HamE. 22 waswho? 

!4 A lldrama 23 A Iassume-thisisanassuInptionbecauseIdidn’t 

!.5 ,6 2 $==_=*=k_ 24 have the ccnwcrdoo directly with Charles Ruf’f. But that 

~5 would be my assumption. 

Page 3 - Page L I 
1340 

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2 

3 

4 

5 

6 

7 

8 

9 

0 

1 

2 

3 

4 

5 

6 

7 

8 

9 

LO 

II 

2 

3 

14 

!5 

Pagt5 

Q Your undcrstandin~ from hk. %‘ainor is that hk. 

Ruff told Mr. Trainor to have you invoke these privikxes. 

Is that fair to say or not? 

A WeII,that-Ididn’t-Idon’tknowthaMr. 

Trainorcwsaidthattomt,soIwanttobcclearabout 

that. ButitwasmylmdcrstandingitwastheWhiteHcnrx 

counzl. whctbcritwasspcelfreallyh4r.Rufforwktkrit 

WasCborylMiIIs-butIassume itwasMr.Ruffthat 

actually made that fmal decision. 

Q YourbestmcoIkct.ionisthatyouwemnottold 

tkspec8.cidontityoftkWbitcHousceouaselthat-in 

other wxds, your assumptiou ia it’s Mr. Ruff, but you were 

ncvergivenanameastowtroitwastbattoldyoutoinvakt 

privilege? 

A That’s my IccoIIection. 

Q ByproccssofeIimination,Itakit,theResident 

0ftbeUnituistamsneverdirectlyiastrudedyoutoinvdre 

p+iIege. 

A That’sconect. 

Q AndthcRsidentoftheUnitedStatesnever,I 

takeit,thistinxauthorizcdyoutoanswereitLr. 

A Youxx&mbyt.hatthathtdidn’thaveadirect 

conversation with me? 

Q_ 

A YtXh,t.bt’SCOrECt. 

CXllCtly. 

Q ‘They,” being your attorneys. 

A Yes. 

Q And is it fair to say that you don‘t have a real 

clear understanding of why it is you don’t fall under the 

executive privilege claim? 

A I don’t have a clear understanding. 

Q okay. Now, ox of the privileges you previously 

invoked was the attomey-client privilege with regard to - I 

don’tlaunvifyoumcall,butwithrcgardtoconversatious 

youbadwithMr.BenneaandA4r.Keadall. DoyourecallA Yes. 

Multi-Page= March 26,1998 

1 

Page7 

1 But I’m not sure of that. I hate to even answer it 

2 with - talking like this. They told me. I can’t recall 

3 

4 

5 

6 

7 

8 

9 

1 0 

1 1 

1 2 

I 3 

I 4 

1 5 

I 6 

1 7 

I 8 

I .9 

2 !O 

1 !l 

1 !2 

1 !3 

1 !4 

1 !5 glveuauthaizationforyoutobercltascdfmmtbatsup~’ 

I Ragto 

1 privilege? 

2 A Itbinkthe-bothattomeysreleasedmefrom 

3 that. Now, that’s my understanding. 

4 Q Bothattomeys,beingMr.KendallandMr.Bamett? 

5 A That’SCtxXCt,thespecifiCissueSthatthty 

6 discuscdwiththcm. 

7 Q Okay. And your understanding of your being 

Q Allright. Andasyourmderstandit,youamnow 

aIIowuito answerquestionswithregardtothose 

conversations as weI& cormct? 

A That’swrrect. 

Q Aadwfioisitthatyoutoldyouthatyoudon’than 

to invoke that privilege? Again, is that Mr. Trainor and Ms. 

wheat? 

A That’s correct. 

Q Andwhatlsyourun&rst8ndingofwhyitisyou’ve 

lKalmleaaedfKmltbatplivllege? lnetbuwerd&wbobas 

Pagc6 

Q How is it that you are now able to answer these 

qutstions, whereas previously you were instmcd to invoke 

privilege? In other words, why have you been given 

permission to answer now? 

A I-I’mnotsureIcananswer that. Ihavebecn 

toldbyxnyeounselIeaunowanswer. Iam-Idon’tlcuow 

thatIhavebeentoldspecificaIIy-generaUyI’vebeen 

told,butIcan’teven&llyouwhatthegateralrcasonwas. 

Q Youranswer piques my intezest. 

A hh-hmm. 

Q what gencdy is your understanding abOUt Why il 

isyounowareallowedtoanswer? 

A (No=I’o=.) 

Q Doyouevenknowwhyitisyou’renowallovvedto 

auswu,othertbautkfactthatyou’vebaentoldit’sokay 

toanswef? 

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A llxytoldmewbattbercrtrictionswueintumaof 

- of, I guess, time - it’s my understanding that they went 

tocourtlastFriday,andthatthcrtwereartainguidehnes, 

andtheytoldme,zmdI-now,thelongerItalk,tbemoreI 

thinkithastodowith~ctly--~,Ic~~~tosay. 

Thzy told me the category, and they said I didn’t 

faII into that category. And that’s - and it was, I think, 

havingtodowithspecific,morr:lcgaladvi~andthatarra 

with the President. 

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releasedbyMr.EkaacttandMr.~dallanncstbroughyour 

attorneys. 

A That’scorrtct. 

Q Have you ever heard the term, “joint defense 

agleun&‘? 

A Yes, I have xcad about it in tht paper. 

Q It’safairIyrectmt-wc~ithasreccntIybeen 

d&xxxdintkmedia,andit’sson&ingyou’vebaxmx 

famiIiarwithorA bgu&’ familiar with. 

Q Doyouknowwhethtrornotyouhavewbatis 

som&mcs called or loosely called a joint defcnst sgnancnt 

with regard to your representation? 

A I do not know. 

Q TothebtstofyourknowIedgt,Itakeittlxmfroi 

youranswerthatyoudonotlmow,thatycuranomeysbrwe 

notdiscxlssedwithyouandhavenotaskcdywtocoascnttoa I 

joint &fens2 agnxmeut whereby you would share information 

Page5-Page8 
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1341 

U.rltLPsar TM March 26.1998 III__ 1 mmfj” _--- _- -_,-_ _ - 

page9 Page 11 

1 withsoxneotber~orsrrmeotkrwi~orsomcotba I Q wbcn you say “indcpendcnt knowledge,” 1 don’t know 

2 suspect in the iWestigatiou. 2 wbattbatmc8n~. lmean,doyouin~-andI’mnotsaying 

3 A well, mphrase that again. 3 tkre’s anything Wrong with that. You’re ax?ainly free to 

4 Q Okay. A joint defense agrcemmt basically is an 4 dothat I’mjustlzyingtounderStandifthxisan 

5 ~tbyY~attomcy~samcothaparty.usuallY 5 intention to provi& - let me withdraw the question. 

6 au&erattOWy- 6 You were questioned twice before in this grand 

I A Mm-lxuml. 7 jury, correct? 

8 Q -tOsIlSeiXifCUIcatiOti. 8 A T%at’seorIeet. 

9 A h’h-hmm. 9 Q After your grand jury appeaxanas, were you 

0 Q And to share information about the questioning by 10 &bri&d about what you told the grand jury? 

1 tk govemment of you- 11 A Iwasdcbrkfedbymyattomeys. 

2 A hb-hmm. 12 Q ~yOUknoWVhCthmyOurattorneyssharedthat 

3 Q And as you understand it, them is no such formal 13 ckbriefiug with other attomeys? 

4 agIumenttoprovideinf~fIwn-tbeinformatioIl- 14 A IdoOatknOw. . 

5 whatwequestionedyrniabout. Isthatfairtosay? IS Q mdttreygctyour conscnttodoso,toshaIetllat 

6 A That’SfairtoSay. 16 iufoimatiou? 

7 Q Okay. Soasi&fromwhtlxrtlzreisaformal I7 A NotthatIrecall. 

8 rgrmnent,*you lLdamndtbuck~doyoulmvtany 18 Q Okay. Letm-I’Hmoveentoanewtopie. 

9 un&rsumdingofwbetbertbernisaninfolmal~t 19 Now, wkn you were previously before the grand 

o wbueby your attorneys share inform&m with White House 20 jury,Ibclievtitrmscratbefvstday.~mwent~~ 

i eounselorMr.BcrmettorM.r.Keudallorotkrattomeys21 tbesev8riousaikgoriesofprivi&thatyou’renowfreeto 

2 umueetedwiththem? 22 talkabol&mdidn’tgetintotbesubst8neeofumvasations 

3 A Would you ask M that again, plea& 23 becauseoftkprivi&eindiaition,andInowwantIoanne 

4 Q Your best UndcrstandiDg is there is no formal 24 backtoitandtrytogothroughasmanyasIcantoday. 

5 anan8emmf no formal Sgrcemn~SUChaSwhat’Ssometima 25 And I’II try to do it chronologically eventually, but fti 

Page IO Page 12 

I called a joint defense agrument. 1 I’ll just do it topically. 

2 A That’s cOrXC% 2 Oneofthctopicsyouwereaskedabouthadtodo 

3 Q Doyouhaveanyunderstandingofwhzthertlxreis 3 witbaamvcrsationyoubiidwitbtbeResi~taboutMonica 

4 an informaI arrxngement? 4 Izwidcy. I believe - obviorrsly, your reooktion should 

5 A May I step out for a mCrment? 5 go~butIbelieveyougavete&nonytothecffeettbat 

6 Q sure. 6 yourbestrcco~ent.ionwasyoubadonecclllvcrsatimwithtb~ 

7 (The witness was excused to confer with eouusel.) 7 Presicknt about Moniea Lewinsky after tk story broke. 

8 THE FOREPERSON: h-k Hcmreich, you’re still uncb 8 AndwewunusingJrmuary2lstof1998asoortof 

9 oath. 9 tkdateaiwbkbtbestorybroke. !?toconvasatiaisafter 

0 TEE FITNESS: Okay. 1othatdatewattheonesyoutookpIivilcgeon. AndyaltooL 

1 BY MR. BAFiGER: 11 privilege on omz eouversation with the Fksideut 

2 Q Ms.Hemreich,asbcstIrecollectmyquestion,or 12 Doesthatringabell? 

3 atleasttheintentofmyquestionwaswlxtlxrthercisan13 A YCS. 

4 informalan-mgumttosharcin.formatimwitbWhiteHousc 14 Q Okay. Now, my questiou is - it’s long-winded to 

5 counsel or the President’s counsel. 15 gettothequestion,butamyoutellusaboutyour 

6 A I don’t have any indepeudent knowledge of an 16 umvasatioawithtbcResidentaboutMoni~Lcwinsy! 

7 informalarrangcment. skingknowlcdgebetwcal-letmc 17 A DOyou--tellmewhatyouwanttoknowaboutit 

8 malcesurewbatyousaid -withtheWhiteHou~ecounSel? 18 Q Tell us basically - your testimony was. it WBS a 

9 Q I don’t mean to be oblique. Basically my question 19 fairly short cmversation, as I rcdkct. 

10 hastodowith,forexample,ifawitnessisquestionedby 20 A- That’s Correct 

II thegrandjury,awimessismetotalkwithwyone~ 21 Q And that the President instigated the topic. 

IZ chotxe. And my q&on simply is, is there an intention 22 A Yes. 

3 thcntopasSontoWbiteHousecounxlortbcRcsident’s 23 Q Okay. Tell us, as best you recokct, what the 

~4 lawyers what it is the grand jury asks you about? 24 conversationwas. Telluswbatbesaid,wbatyouseid,as 

!5 A I don’t bave any independent knowledge that there is. 25 best you recall. 

Page9-Page12 
1342 

Mull 

Page 13 

1 A What he said was, “I didn’t do this. They don’t 

2 believeme. lkywcm’t” -eitberThcydon’t”orTky 

3 won’t - “They won’t bclicvc me,” I think it what be said. 

4 “I didn’t do this.” 

5 Q Okay. Did hc give any explanation about what 

6 “this” wZIS? 

7 A No, he didn’t 

8 Q He just &am&r&d it as “this.” 

9 A That’s COITtct 

0 Q okay. AnythingCkhCSaid,a~b&yOUrecall, 

I othcrthankdidll’tdOthis? 

2 A No. 

3 Q Now, you also invoked privilege ahout amvasaticms 

4 youhiwirhMr.-mdMr.Kmdall,andthatwasintk 

5 sccondcategory_Idon’tknowifyourecallthatwasim 

6 your sewnd 

7 attorney-client area. 

8 Ixt’staketboseoneatatime. Fi.rst,withregard 

9 to your ccmvusation with Mr. Kendall, did that amvarsati~ 

0 containthetopicofMonicaLewinsky,ifyoumcall? 

1 A Tobehonest,my answerwouldbe1thougbtso. 

2 Q Okay. 

3 A Tobeveryclearaboutthat,I’mnotsurewhat’shr 

4 said to me, though 

5 Q Okay. Your impression - 

Page 14 

1 A My impression. 

2 Q -- and peraption is that it was about Monica 

3 Ixwinsky. 

4 A That’s correct 

5 Q canyOute~uSWhZEtheCOnversatiOUoccurred? 

6 Inotherwords,wasitattheWhiteHouse,wasitontht 

7 teleplxme, in persoq at his office7 Where was the 

8 CXmwrSatiOII? 

9 A It was at - my recollection is that it was a 

o combination of both the phone and at the White House. 

1 Q You wem at the White House on the phone? 

2 A I think - my recollection, again, it was the same 

3 day. Itwasaumvusationontbtphone. Hetbatcameto 

4 the White House. We bad a subsequent convasatioa at the 

5 White House on the same topic. 

6 Q AndusingtheJanuary2lstdateasoursortof 

7 bcnchaark,wasthisamvcrsaticmwithMr.Kcndallaftc?that 

8 date or befoxe? 

9 A It was after that date. 

0 Q Approximately how long did the cc~~~vcrsation on the 

1 phonelast? 

2 A It Was kSS than five minutes. 

3 Q He called you or you called him? 

4 A Hecalledme. 

5 Q Andthepqoseofthephonecallwastoarrange 

PZlgP March 26,199X 

1 tk face-to-face meeting? 

2 A That’s CQIYWt. 

3 Q Okay. Andhtcameovertoseeyouthesamed: 

4 A That’s corzect 

5 Q Andbec.axnetoseeyouattkWhiteHouse? 

6 A ‘Ihat’s C0XTeCt. 

7 Q How long did the conversation at the White House 

8 take, approximately? 

9 A Approximately five minutes. 

0 Q Tellusasbestyourecallwhatthatconversation 

1 WZiS&OU~WhSthCSi3i~Whtp.lSd. 

2 A kfr.Kcadallapkedm:to~for~hooks,andbc 

3 g2T~metbetitlcsofthem. Andrbslhcilxiicatedthathe 

4 wolJldbcclnnil#lodlcwhiwhitHouscuKlthlltWwould-md 

5 thatkwouldkthareatacataintime,andtoletbimknow 

6 wbat1think. 

7 Q LetmeseeifIunderstandyou InUrephone 

8 con~tion lo gave you tlx infomration relating to, he 

9 wautalyoutoloolcforsomabo&,andtbatkwouldcomc 

10 overtopicktkmup? 

1 A Cormct,andatleastindicatetohimifIhad 

2 located&m. 

3 Q Okay. Doyoureui&onthephoneconversa&, 

4 wbatelszksaidaboutthebooks? I-1 asaunzkgavc 

5 yousomemominformation. 

Page It 

I A ~gavemtitks,asIrccalk 

2 Q Andwhatvmretbosetitles? 

3 A We~~can’ttc~youexactly. Icante~y~uonc 

4 wasgcncrauycallcdIbcPrcsidaltofthcUnitaiS~alld 

5 tbenascumdbook,Idon’trecallthttitle. 

6 Q IfImggeSedapossibletitletoyou,wouldit7 might it rcfish your recollection? 

8 A Yes, itmigbt. 

9 MREMMICX Letmetbrowoutsomepossibilit& 

o Bytkway,mynameisM.ikeEmmick. 

1 THEwlTNEm uh-huh. 

2 MR WISDIBERG: Ya Mr. Barger forgot to introduce 

3 him. 

4 MREMMICK: Thtvoiafiomtkeastovcrhe. 

5 BY MR. BARGER: 

6 Q I’msOrry,Iapok!gk. ThisisMr.Emmi&and 

7 that’sh4r.wisenbcx&whomyou’vemetintkpasL 

8 A YCs,Ihave. 

9 Q And I doubt very seriously you forgot. 

0 A 1 havt not fOr@tcn him. 

I Nice to meet you, Mr. Emmick 

2 BYMR.EMhiIcK: 

3 Q Thankyou. WasoneoftkbooksTheNotebook? 

4 A TheNotebook? 

5 Q Yes. 

Page 13 -Page 16 
1343 

Mull i1 A 

2 Q 

3 A 

4 Q 

5 A 

6 Q 

Page li 

No. 

WasoneofthebooksabookbythenameofVoxl 

No. 

WasooeoftbeboohabookbytknamcofOyV~ 

Oy Vey? No. 

WasoneoftirbooksabcokbytlznamcofGctk 

7 Love? 

8 A No. 

9 Q You would have ~beredtbatonc,Itakcit. 

0 A I’mnotsureaboutthat. 

1 Q IfIcouldjustfollowup. Howmaaybookswueyou 

2 askedtohakfor7 

3 A hfyrCC&CtiOnis,I~asktdtol~fo.rtwo. 

4 Q Chcoftbemwastkhsidmtoft&titalstatts, 

s and you don’t renzmberwhatthtothrbookwas? 

6 A I don’t Icmembcrthetitleofrko&rbo& 

7 Q Howwastkotherbookdescribal? Wasitsimplyby 

8 title,orwastheresomedesaiptionofthEnatureofthe 

9 book, the size of ti book, hardback, softback, how old, 

0 anything like that? 

1 A Ithinkhctoldmethctitleofthcbook,andthcn 

2 bedidtellmthegcneraltopicofthebook. 

3 Q Andwhatwasthtgeneraltopicofthebook? 

4 A ItwasabookonTheodoreRoosevclfasIrccaIl. 

5 Q Anddidyouwritedownonsomcskctofpapcrwhat 

Page 18 

1 tbttitleoftbtbook~tohtlpyouasy6u~forit? 1 

2 A I probably did. 2 

3 Q And did you keep that piece of paper? 3 

4 A I doubt it. 4 

5 Q Did you find the book? 5 

6 A Yes, I did find that book. 6 

7 Q Did you give it to Mr. ?hda.ll? 7 

8 A You know, I don’t rememberifIgaveittoh4r. 8 

9 Kendallornot. 9 

0 Q What did you do with th book? 0 

1 A WeI& I - I just don’t remember. ItbinkI 1 

2 probably gave it to Mr. Kendall, but I can’t say without a 2 

3 doubt that I gave it to Mr. Kendall. I may have left it 3 

4 whereitwasandjustindica@dtoMr.Kahllwhereitwas. 4 

5 Q Wheredidyoulookforthebooks? 5 

6 A I looked for the books in the Oval Office and in 6 

7 the study off of the Oval Office and in the President’s 7 

8 diningrm. 8 

9 Q How did you decide to look for he books there? 9 

0 A Mr. Kendall asked me to look for the books the. !O 

1 Q Is that when the President keeps his books? !l 

2 A ThepRsidentkeepsallhisbooksthe. 2 

3 Q Canyougiveusadcsctiptionofhowmwyboaksaud 3 

4 wherctbcbooksareinthosethnzroon~~? Idon’tbavea 14 

5 mntalpicturcofsortofabookcase,forlackofabettcrword. !s 

r 

.PllgC” March 26,1998 

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A Well, you’ve pictures of the oval 

Page 19; 

Offix. I’m j 

sure, and th along opt wall, if you’re looking at, say, the 

deskundtothTrigfisd3cwarctwobookcases. ADdsotheTe 

arebooksinbothofthosebookcases. 

Them arc books in the President’s study. 

Tlue’s-onewallisaLmostenti~lyabookcase. Andin 

tkdiningroomtkrc’safewdispiaybooksout,mostlykind 

of out flat and - and, actually, there’s a third place, the 

ballwaybetweentkOvalOffiaandrhcdiningrwm,that’~ 

a bookcase. 

Q whercdidyoufindtktwobooksyoubadbamasked 

tolookfor? 

A Well,IfoundthecmebookthatIwascertainofi 

tkhaloffia. And,inreality,Ifoundthreebodcswith 

thesametitle,thcohrone. SoQ -hreebookswiththcaamctitk,tiThodorc 

Roosevelt - 

A ‘IIx President of do United States. 

Q oh, Tht Pr&knt of the United States books, yol 

found three of thcsc. 

A hfm-hmm. Thrcewiththtsametitlc. They= 

diffuent authors, different - 

Q Isee. DidyougiveaUthreebookstoMr. 

Kendall? 

A Ibeh!eIshowcdthcmtoh&&ndall. 

BY MR. BARGERz 

Page 21 

Q WasTheprsidentofthcUnitedStatesbook 

different than tht Thdore Roosevelt book? 

A Yes. 

BY MR. EMMICE 

Q And maybe I didn’t undcrstmd. Whc did you find 

the thnze President of the United States books? 

A IthinkIfound~thrceinthe~~Mficc,but 

I’m not actually certain of that That’s my recollection 

right now. 

Q Asyoulookatthoscbooks-I a===thatyau 

lookedatthmabitforinscriptions,anythingliketbat,or 

did you? 

A Idon’trecallifIdidordidn’t Thatwasnot 

SU&hhgheh8daskcdmCto~Imcan,togefsO 

I - I’m not sure I did. But I may have. I just - I don’t 

know for sure. 

Q If you had and, you had m the nazq Monica 

Lewhsky, would it have struck you? 

A I think it dvould have. 

Q ~didyoufhdtheTheodoreRoosev&boo~ 

A IfounditinthOvalOffice. 

Q ho? 

A Yes. 

Q Having found those books that you were asked to 

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Page21 

look for, did you continue to look? 

A Tell me what you mean by that. 

Q Here’s what I mean. You were asked for look for 

two books. 

A ~~XI-~IIL 

Q To find two books. I would have thought that yet 

wouldhavestartcdinthcovalOff~~your~forthose 

two books. 

A h&n-hmm_ 

Q And you found those books. 

A hh-hmm. 

Q Butyoustillwentouandlooked. Why? 

A I-IcouIdn’tfmdtbeRoosevelt,theThe&ore 

Roosevelt book at fvst 

Q Allright_ Sowhathappenedis,youlookinthe 

Oval Office, you fmd the three President of tht United 

states books. You can’t find lkodele Roosevtlt tbac. You 

thgOtOtbCShlCt&tllCildl~tllCdiaiag~dyW 

dccidetogobackandrcnmtksearchoftkOvaIOffiia, 

arid that’s when you find the Theodore Roosevelt book. 

A Ithinkso. Itmayhavebeen,actually,thatMr. 

Kcndallcamc,nndwcbetblnokedtogetberattbatpolntand 

3 tknfoundit,thtsecondbook. 

4 Q You mentioned at the beginning that you thought 

5 this request related to Monica Lewinsky. 

Multi-PSigP March 26,1998 

1 

I Page 23 

1 Q Okay. 

2 A AndIthinkthzotkr-thethreeTkPresidentof 

3 the United States books were hardbound. 

4 Q Anddoyourccallwhetherthcrewexany 

5 inscriptions from Monica Lewinsky? 

I 6 A Idon’trecallthattkrewcreany. 

7 Q Your view is, you probably would have runem8 tbatbadyousan-iftbcremnandyouhadsacntbcm, 

9 you’d xemembu them. 

1 .O A Ititinkso,ycs. 

1 ,l QbyW KZ?lQIlberwb=iiticonntctiOllwitfitbCJaIl~ 

1 2 2lsttimeperiodtllcMcmicaLwinskymaacrsatofberrmr 

1 3 public,wJminrcIation&iptotbatdidMr.Ka&Ucallyou 

I 4 ontkplKmeandaskyoufortlxxzbooks? Sam&y? Day 

I S afbzl? 

1 6 A No,Ithinkitwas,youknow,somet&after,but 

1 7 itwasn’t-itcertamlywasn’tthatday. 

1 8 Q whattimeofdaywasit,approxima&ly,thatMr. 

1 9 KendauallledylJutnbnveyallenkfnrtilQn? &iming? 

2 xl Afternoon?? Evening? 

2 !I A Well,Iknowhecameinarotmdnoouerso. 

2 2 Q Htc8mcaboutnoon. 

2 13 A Mm-lmm. SohcmybavecekdmcatlO~orllzOO 

2 14 or 11:30. I don’t know. 

2 :5 Q Andthcamversationmtkphoneyoucstimatec8 

, Page 2. 

lasted kss than five minutes. 

A That’smmct 

Q T~uscvuytkngyoucan~aboutthe 

conversation. Hca!zkalyoutolookfortllcsebwkr,mdbe 

gave you &suiptiorls of rile books, the tit.& fa uemple? 

A Thttitlesofthcti. 

Q Whatelsedidktellyouabout-whatelsedidk 

say-didhesay~heneedcdyoutolookf~thtbooks? 

A No,hedidn’tsay~Inaedcdtol~forthcm 

1 Q Wbat,ifauything,didhtsay? 

1 A Idm’t mmemberimytbingclscksaidtomcabout 

1 it 

1 Q Did he give you any explanation at all, my umtex 

1 atallnbmtwbybewacbavingyuulookfortk&~? 

1 A No,notthatIrecall. 

1 Q Yousaidearlierthat-audImaybe 

1 wwbatyousaid-but,inesscacetbatyour 

1 assumption was, or your perception was tlurt these book 

1’ somehow related to Monica Lzwinsky. 

21 A Yes. 

2 Q Why did you make that assumption or conne&o+ 

2: A Idon’tkoow. Imean,eithzhesaidit,butht 

- 2, maynothavesaidit,aadIdon’trecallthcexact I 

2’ amvaxaticm. OritwasaftcrJmnxuy21st. Itsaancdtobc 1 

2 

Page 22 

1 A IthoughtsO. 

2 Q why? 

3 A Idon’t rananber. Idon’t rcmemberifMr.Kmdall 

4 saidthat. Idou’t-Idon’tknowifImadethat 

s assumption. I - I just don’t remember. 

6 Q Did be ask you to look for anything else? 

7 A NotthatIrecaIl. NotthatIrecall. 

a Q Did you look for anything else? 

9 A No, I didn’t look for artything else. 

0 Q Having found the orx book, ‘The Resident of the 

1 Unital States,’ why did you continue to look for other books, 

2 l%ePresidmt~ftbeUnitedStatcs,ordidyou? Werethey 

3alIthmetog&lcr? 

4 A IthinkIwaSmillloOkingfortheThbodon 

S Roosevelt book and then umtinuiug to look at all these 

6 books,Ifoundtbtothcrtwoaswtll,theothertwo,The 

7 President of the United States. That’s as I recall. 

B I do hundreds and hundreds of things every day, and 

9 tonmmlbcrexactlyhowIp~scdthrollghcachoncofthan 

D isalittlebardto remember, but -- 

1 BY MR. BARGER: 

2 Q Just a couple of follow-ups, and you may bavt 

3 cevuedtbis. ?bcboolrsyoudidfmdwuetbeyba&oundol 

4 softbound? 

5 A I think the Roosevelt book was softbound. 

1 

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5 tbepfimcfacusofwllatMr.Kemlallwasworkiraonattbat I 

Pace 21- Pace 24 
March 26.1998 

Page 2. 

1 time in relationship to this, you h~ow, representing tk 

2 President. 

3 AndIbadpossiblyattbatpointmadintk 

4 aewspapatharshehadgivcnhirnscancgifts,andImightha~ 

5 just ma& all tlnse assumptions at that point. 

6 Q HowmanytirncsbefatthishadMr.ICcn&llcaUed 

7 you? 

8 A since I’VC kDOWn him? 

9 Q Yes, I guess. If that’s too many, we’fl nan-ow the 

0 topic. 

1 A HowmanytimesbasMr.Kendallcalledmeintb 

2 lastfourorfiveyears? 

3 Q Lots. 

4 A Hundreds. 

5 Q Howmanytimeshashta&edyoutolookfor 

6 something? 

7 A Idon’tknow. Itmaybetionlytime. But1 

8 wouldhavctothinkaboutitalong-agoodloaBtimto 

9 thinkifkhadeveraskedmetoloakforanythingkforc. 

0 Q ~thesewuegiftsfromMonicakewin&y~ho~ 

1 manyotkr&eshaskevua&aiyoutolookforgiftsfrcun 

2 MonicaLewi&y? 

3 A Idon’ttbinkhe’severaskedmetolookfor 

4 anytbingelselike-intbisperiodoftime,sinceJanuarl 

5 21st. 

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Page 2t 

Q Howsoonafterbecalledyouontbepbonedidbe 

come over? 

A Itseemedlikeitwas,youknow-asIbadsaid, 

eitkrkhadcakdmebehKgn 1O:OOand11:3O,soitwas 

either from an hour-and-a-half to 30 minutes, you know 

I don’t recall. Sometime late morning he called 

andtkncamcinaroundnooa. Hemayhavesaid,‘Well,I’ll 

k over there in 30 minutes.” I don’t rcmmber. Orkmy 

have then said, “I’ll be over tkre in two llours.” 

Q Allright 

A But I think it was maybe 30 minutes or so. 

BY MR. EMhfICK: 

Q Actually, I wanted follow up on couple of 

things. YmImmtimdthntMr.-honlyaskcdyoum 

lookfortbisonctliingdutingtbistimcpcriod. 

A hfm-hm. 

Q What about during otkr time periods? 

A We&I-Itbinkthatmaybehebadaskedmetbat 

too. I don’t recall, but I’d have to think about it, you 

.D know,alongtimebccausew’rtcovaiag,wkt,thruorfour 

11 yearsberc. Andso-but,youlmow,Idon’trecallthatbc 

!2 didorunderwhatcircumstancffkmighthaveaskedmcto 

!3 lookforsometbing. But hemaybave,yeah 

!4 Q Whywunyoutbeoneaskedtodothcsearchingfor 

!S these books? Were you tk logical choice? 

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Page 21 

1 A I-Idon’tmcallotbertbantksecouplebooks. 

2 Imean,Icouldgoback. Again,there’ssonxinythingsthat 

3 goon,and,klicwme,wrcgctenoughdacummtreq~and 

4 requests for things that it begins to get a little blurry 

5 after a while. 

6 But I don’t recall being asked to look for otkr 

7 specific items ratkr than documents. I just don’t recall 

3 that. 

? Q Istbereanyoneelsewbowouldbavebeenaskdtc 

I look for the items that might respond to that subpcena? 

I A I don’t know. 

1 Q But you would think that you’re tk logical choice 

! A Iwouldtbiakso. 

I Q WacyouaslrcdbythcPmaident’sotherattomeyia 

s tbcPaulaJonescase,Mr.Bemret&tolookforanyitems 

5 A No,Idon’treeallbavingMr.Bennettaskmto 

I look for any items. 

1 Q DidanyboclyonMr.Bennca’shehalfaskyoutolook 

3 for any items? 

J A No,IdonitrecalltbatMr.Bennett-anybodyon 

1 Mr.Bennctt’sb&alfaskeclmetolookforanyitcms. 

2 Q WhmtkPmidentwas subpoenatdforitemsin 

3 conmxtion with the Paula Jones case, do you have any 

4 information ahout who the President amurged for to lo& for 

sitems? 

Page 2 

A I think that tk President probably indicated to 

Mr.KcndPllromc~~thatb:Jhouldworkthrouehmfor 

things like that. That’s my guess. 

Q Wkn you say, “things like that,” what does that 

mean? Wbat are tk “tilings like that”? 

A Well,IthinkifhencedstoseethzPresident.k 

ahouldcallmc,orifk~totalktothtPresidentabout 

sonxthhg, to work through me, or if k needs to send a 

documenttotkPresident,tosendittome. 

I-that’susually-Mr.Kendalljustscemsto 

hanwor~tlrroughmeforthelastthreeorfourycars 

Q Waeyousentacopyofasubpaenathatwassentta 

-ItttinkitwassenttoMr.Kendall. Itmigbtbavebee 

sent to White Hour counrel’s office, or both, asking for tlx. 

pruductimi of cut&i items from the F?esidcnt? Were yau 

asked to look for otkr items? 

A No. I have not seen a copy of tbc subpoena listin 

specific items. 

Q Have you seen a copy of tbe subpoena asking for 

general items? 

A The only subpoena that I’ve seen lately is one tbir 

wtek I received from the Counsel’s office relating to 

documents concerning four peopk, I &ink. 

Q Youweren’taskedtolookforanyitcmsatall,as 

opposcdtodocummts? 

PXJP ?5-Paw78 
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Q ~~undemand,yourbestrecOllectioni~,the 

onlytimCyouwercaskedtosearchfofwilatMr.Enxnick~ 

cbaractaizedas”i&ns,‘whichwouldincludctbingslik 

books,tangiblegifts,thatkindofthing,theon.lypaxm 

whohasaskcdyoutimakesuchaxafchwashfr.Kcadsll 

A That’sasIrecalIit Imean,Icouldbehatand 

think about that a while. I just - it’s not a question 1’~ 

thought about and - 

Q Okay. Well,give it somcthoug_ht. 

A Okay. 

Q Ifyouranswcr -ifyouthinkaboutitwhik 

you’re here and you mber somthiag diffcrcn obviously 

bringittoourattention. ButatIeast,asbestyourccaII 

ri&now,thiswastkcmlytimeyou~askaltoszi& 

for what 1’11 call gifts. 

A hhrhmm. 

Q Books, hat pins, T-shirts, anything like that that 

the Rrsidcnt may have ken given by Monica Lewins&. 

A That’s as 1 d it - 

Q Okay. 

MUlti-PltgCm March 26.1998 4 

3 Page 31 

I other one to him. I may have left it there as All. 

2 The reason I’m - I’m just not certain, because I 

3 lcnowIleftthtoncsrctof~ksthcrebecausewedidn’tknc 

4 whichoaeitwa$gndhmayhavcjusthadmeleaveallofit 

S thae-Imen,th:~dbook,thtbookIdidfindthcn. 

6 Aodwt~dofformdtbataaetogethcr,asIrrcall,because 

, 7 bytheti.nxkgottheremaybcitwasbcforeIfoundtha 

8 Roosevelt book. But I don’t really nmmber. 

9 Q Didyougothroughallfourboo~tolookfor 

I 0 insaiptions or 0th~ ways of linking the book to another 

I I pcfson? 

: I 2 A 1 might have. I don’t xmemberifIdidordidn’t_ 

I 3 I just don’t rcmcmter. 

I 4 Q Doyoukmwwhehexhedid? 

I 5 A I-Idon’t-rcmcmberifhcclid 

11 6Q Wasitjusttbctwoofyouwbowacamductingthis 

, 1’ 7 seal&thisfoIIow-upsear&aftcrhcgotthz? 

II B A AslrecaIl,yeah Idon’t~thinkNicok 

I! 9 ScligmanwiUtkx Iman,tllcE’salwq5that~but 

21 D IthinkitwasjustDavid. 

2 I Q Andwhcnyouwaclookingfmtk~beforek 

2: 2 gotthcrr,wasitjustywwhomrrt~lookingf~tbc 

2: 3 books? 

24 4 A YCS. 

2: 5 Q was the hesidcnt present? 

1 Page 34 

I A No,tkPresidentwasnotpresent 

2 BY MR. BARGER: 

3 Q Waskthcnw&nMr.KmdallcaUal? I-was 

‘ 8 hethereatallduringftnypartofthatmozning? 

: s A I don’t b&eve so. 

t 5 BY MR. EhihfICKz 

. I Q ~youknowhowthusebookswereidcdificd? In 

I 1 othcrwords,didMr.~say,“Wc’ve~askadtolodc 

5 P forLxxks,nndhacaretkbooksthattbcPrcsidcntsnidk 

IC 1 got?’ 

11 IA No. Isaidthat’swhy-no. That’swhyI’mnot 

13 ! -Idon’tknowthat-thatitwasan~~~Icould 

I3 I baveme&tbtitwaorcgard&giffsfrctmh4onica~, 

11 4butIwasn’tartaink.causeIdon’tbctimk-kdidn’t 

I: 5 getintoanyofthat HccerGnlydidll’tsayanyofthaL 

II 6 Q RtgardlessOfwfiatImtCrit~tO,thOUgh, 

1’ 7 didkindicatewb&uthetitlesofthebookswenobtaincd 

II Bfromthehdent? 

I! 9 A He didn’t indicate, that I recall. 

2( 3 Q Didyw i%sumethatthePEsidmthaclgivenhimthc 

2. I titlesofthosetmoks? 

2: 2 A Iassumedtbat,butIctrtainlydun’tknowthatf\ 

2: 

24 

2: 

page 3a 

I A - for right now. And I’m relatively artain that 

2 I - I’d have to - it’s not some&iq I’ve thought about 

3 before. 

4 BY hlR. Eh4MICK: 

S Q What happened to the books? 

6 A You know, I’m just sitting her - I think I gave 

7 one of them to Mr. Kendall. 

8 Q How did you decide which one? 

9 A Well, after we finally found the Roosevelt book, I 

o think I gave it to Mr. Kendall, but I’m not absolutely 

I certain. AndthenIlefttbeotberbookswbeixtbeywcrcin 

2 the oval office. 

3 Q ~WithreSp&tOthCthrC!C’h~idcntOfthe 

4 unimIsmLJbcQks.youfound~yousIYJwatttlanmMr. 

.5 Kendall, and you put them back. 

6 A That’s correct 

7 Q hyouknowrqthiqjaboutwimtwzhokcdatwitb 

8 rtspecttothoscbooksthatwouldcauseyoutoputthcbooks 

9 back since those were the books you wexx looking for? 

:0 A I don’t think Mr. Kendall also knew for CcRain 

!I whichoncofthosebookswmthcbookthatbewaslook@ 

2 for. 

:3 Q Isee. 

4 A Andso-andkjust-hejusthadmekavetlxzm 

5 where it is. And I’m noOt absolutely aatain that I gave the 

Page 2! 

A No. I’mnotsurcbewasawamthatanybodyasked 

him to - that he was subpoenaed to look for items in 

relation to that cast. 

MR. EMM’Ia That’s a. 

BY MR BARGER: 

3 sure. I 

t Q Doyouknowhowthosebooks~intotheiibrary? 1 

s A No, I do not know how they got into the library. 

Pape 29 - Page 32 
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Page 33 

Q Had you seen those books before? 

A I don’t Kcah Secmg those books before. 

BY hfR. BARGER: 

Q Wknyouwemtalk@earkrabouttktimeofday 

tbatMr.Kmdallarmoin,wbo-Idon’tknowiftbis-this 

maynotbetkrightte&nicaiword-wbob~biminto 

tk White House? 

A who&at’edhimin? 

Q Whocleamdhimin? 

A Idon’tknowwhockamdhimin Itcouldhave 

been the counsel’s office. He may have had a meeting 

upstairswiththurL Idonotknow. 

Q Yourtm&stmid@wknkcahedyeuwas-now 

tktyoummtionaiitmrsperbapstkcoun4’sofXiwas 

kontkWbiteHouscgrouodswknkealkdyou,orwask 

at his office or outside of the White Hws grounds? Or 

wbat’syourperceptioooruodaaendiagofwktkrkwasat 

theWhiteHouseornotatthcWhiteHouse? 

A Idon’t remember. 

Q okay. otbathanbir.Ken&hkvingyoukokfor 

tkse~hiiveyouhadanyothercenwrrat&uwitbMr. 

Kendall about the Monica Lewin&y matter? 

A Idon’tthinkthatIhadanyconversationswithh4r 

Keudall - any other wmmsatiom with Mr. Kaxbll about t.k 

Monica Lewinsky matter. 

Page 34 

1 Q How about any attorneys for tk President, wktkr 

2 it’s Mr. Kendall or any associate to h4.r. Bennett, or any 

3 associate any of attorneys in White House 

4 couusel’s Offlce? Have you bad soy coovefmmms with any 

5 other attorneys - excluding your own - 

6 A hfm-hmm. 

7 Q - about Monica Lcwmsky? 

8 A Well, I’m certain that I’ve had conversations with 

9 attonqs in my counsel’s off~oe about Monica Lewimky. 

0 Q Let me - then I’ll be more restrictive. How about 

1 atmmqs associated with Mr. KaldaU? A.& flmlgovmlmcnt 

2 attorneyspaidforbytbctaxpaycrsendtbcWhittHousc,how 

3 about Mr. Kendall - private attorneys?? Any convcmtion 

4 with8nyoncelscas!5ociatalwithMr_KendallaboutMonica 

SLewinsky? 

6 A I know what you’re asking. No, I don’t believe I 

7 have. I don’t recall any conversations with anybody 

8 associated with h4r. Kendall. 

9 Q SowkmyouappearedbeminFebruaiyandyouwem 

0 told tbrougb your lawyer - you were told by Mr. Kendall 

1 through your lawyer to invoke the attorney-climt privilege 

2 witbregardtoyourde&ngswitbMr.KeodaUitwaswitb 

3 regard to looking for these books. 

4 A ButyoujustsaidthatIwastoldbyMr.KendaIl 

5 through my lawyer rather than Mr. Ruff. 

page= March 26,1998 

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Page 3. 

Q Okay. I’m sorry. Maybe I’m confused. Because 

tlrzre’s executive privilege - 

A Uh-huh 

Q - and there’s the attorney-client privilege. 

A Uh-huh. 

Q Are you saying that Mr. Ruff to invoke tk 

attomey-elient privilege with respect to - 

A Mr.Ruffdicln’ttehmeanyth& Idon’tknowhow 

myanomeysdetaminedtbat,ifitwas-butmyattomey 

told me to invoke tk attomey-client privilege the first 

tin% 

Q okay. Wbatisyourtm~aboutwbyitwas 

that Mr. Trainor had you invoke attorney-client privileg 

withregardtoyour&alingswithMr.Ken&Il? wasit 

becauPcMr.KendaUtoldh4r.Trainortodotkt? Itakeit, 

Mr. Trainor on his own wouldn’t just say - 

A A.hIcantellyouis,Idon’tknow. Hedidnot 

tell M. 

IWEF~BBPBRSONZ ?bismaykagoodtimefortk 

0 grandjurytotakeabmak. 

1 MR BARGER: Yes, ma’arn. May the witness be 

2 excused? 

3 THE FDREPERsON: Yes, she may. 

4 MR. BARGER- We’ll come and get you. 

5 (Witness excused. Witness m&led.) 

Page 3t 

1 ‘IHE FGREPERSON: We have a quorum. 

2 MR. BARGER: Thank you, Madam Fomman. 

3 THE POREPERSON: And we’re on the record. And 

4 h4s. Hem&h, you are still under oath 

5 l?rEwxTNEs: Thankyou. 

6 BY MR. BARGERz 

7 Q lvIs.Hernrei~letmcstaywithorgoba&totk 

8 topic which I’ll generahy &am&rim as looking for 

9 things. Itbink”items”wastktamtkth4r.Emmickusedal 

D one point, 

I A Mm-hmm. 

2 Q Andwcaskedyousomequmtionsaboutbadyouban 

3 askedtosearchfor,besidesthebooks,anythingelse. 

4 A JURORZ Louder, pltase. 

5 MRBARGER: &my. 

6 BY htR. BARGER: 

7 Q Iwantedtoaakyouabroadcrquestimintczmsof, 

8 haveyoubeen~-Igucssweshouldputatimcframem 

9 it-let’ssaysincethesummer of1997,whichiswlxmthc 

0 Kathkn Willey story broke, which would include tk fall, 

I October of ‘97, which is when the Paula Jones litigation 

2 geared up, through today, have you ban asked to do an> 

3 scanzksforanyitcms,books,d ocUmarts,gifGyWkrroW, 

4 anyth.ingconnccted with tk Paula Jones litigation or thi 

5 invc?Xigation? 

5 
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luult 

Page 37 

1 Aside from looking for these books, have you beer 

2 askcdbyanyonctodoasearchforanyoftheothertypesof 

3 information that may hc relevant to either that civil case or 

4 this 

5 A Well,Ihadbeenaskedtolookforamespondence 

6 from Kathleen Willey. 

7 Q Okay. Anything else besides that that you’ve been 

8 askedtolookfor? 

9 A In relation to the Pada Jones matter? Is that 

0 what you’re asking? 

1 Q we& remQn her, my question’s very broad- It 

2 inclti anythhg having to do with that civil litigatioa and 

3 anything having to do with the criminal investigation. 

4 A Books, gifts, documen ts? Notothrthanthe 

5 documentrequeststhatcomethroughtheWhiteHousecounscl 

6 andtbeletterstbatIjustmentioned. Idon’trecallany 

7 other-andthebooks,tbetwobookstbatImentioned,I 

8 don’t xecall any other. 

9 Again, if I tltink of any, I’ll clarify the record 

10 on it. 

:1 Q Okay. 

:2 A But I don’t think - I can’t think of any right 

13 now. I’ll think back about it 

4 Q Okay. Let me go through that in a little bit of 

:5 detailPage 38 

1 A Okay. 

2 Q -tomakesure. 

3 A Okay. 

4 Q You said you were asked for contspaadena from 

5 Kathleen W&y; is that correct? 

6 A COrECt. 

7 Q Who asked you to look for that? 

8 A My recollection it was Mr. Betmen, but it could 

9 haWbantbe counsel’s Offlicr. And some of it I might have 

o just looked on my own. 

1 Q All right. Well, but my question - 

2 A IhOW. 

3 Q Iwanttolimititto-youwereaskedtolookfor 

4 cofYcspan&ncc from Karhkm wii, and you believe froal Mr. 

5 Bennett or the counsel’s OffIce. 

6 A That’SaS remember it. And I’m not enthzly 

7 absolutely positive that Mr. Bemxtt asked me or anybody 

8 askedmc,orthatIlcokedoumyowaandsaid, “Oh,bythe 

9 way, I have this.” I don’t know. 

0 You asked me whether sommue hadaskedmetolook 

1 forthings. 

2 Q Right. 

3 A AndI’mtryingtobeclearandI’mtryingtobc 

4 bontsgbaxuse~cannotsaywithoutadoubtthatA4r.J3umett 

5 or that somebody asked me to do it. I may have looked for it 

Pagtrn March 26,1998 

Page 39 

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and volunteered it. 

Q All right Well, let me stay with that a minute. 

A Okay. 

Q Be-cause I’m simply asking to the best of your 

recollection, as opposed to without a doubt. 

A hf.m-hmm. 

Q %‘ioudy, if you want to qualify someth& yo 

m. ButasIiycur auswer, you started out by saying 

Mr.&nnataJkedyoutolook,andthcnyousaidMr.Bcrm 

and the White House office, and then you said, “Well, 

possibly I did it on my own witbout being asked” 

!Soletmjustmakesutewe’reclearlxre. 

A okay. 

Q Totbebcstofyourrecollection,wereyouasked 

1ookforaxnSpondenee fromKatllleen Willey? 

A Totbebcstofmyrecolleetion. 

Q Youwcre,allrigltt. 

A Iwas. 

Q AndyourbestmcoIketionisthat-whoisit 

thataskedyoqilsbcStyoumcall? 

A TotbebestIrecall,itwasMr.Eknneu 

Q Aside from looking for the eo=Fndencefnmr 

KathlccuWii,asecondthingyou’vebazraskedferwuc 

tJxbooksthatMr.Kendallaskedyoutolookforthatwc’vc 

already talked abouq auruzt? 

Page 4t 

1 A That’s coned. 

2 Q Okay. Anything else you were askd to look for 

3 b&cksth~hvoitems-thcsztwo-%ems~istkmosg 

4 word-tbosetwotopicsorcmqorim? 

5 A I don’t recall anything else. 

6 Q Now, I thought you mi@t have alluded to possiit 

7 bcinga&edtolookforsometh@-strikethat. Ietmcsk 

8 itthiSWay. 

9 InthecourseoftheciviIlitigationaudinthc 

0cTclluw0fthisaimiaalimre;rtigation,subpanashavc~ 

1 issued Wexeyoueveraskedtohkf~anyitemsin 

2 c0njtmctionwithsubpanasWhadbeenissued.eitbah 

3 thtcivilc.ascoriatheuiminalinvestigation? 

4 A Subpocaas just for the President? 

5 Q Well,anysubpacna. Inothcrwads,onaxasioua 

6 subpocnawilibei.ssdbythisoff-~oztothWhiteHouseto 

7 lookforcuiaindccumentsortothtPresidalttolcokfor 

8CeTtahdocUmeniS. 

9 Haveyoubeenaskedtodoanyseamlxsin 

0 conjunction with the production of dccuments related tom 

J jUry SUbpocaas? 

2 A Ye!& ~mea&ifyou’setdking&out-cutaidy 

3 mbavcbcmaskaito-theWhiteHoushasbecnaskaito 

4 Ioakfordocumcnts,andtocatcgor&-Imcan,dy,it 

5 haarnesahortaftaawhilc,~uscmgetsomany~t 

Page 37 - Page 40 
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Page41 

requests from either the House. the Senate, the indepencJa% 

counsel. 

You Imow, exactly -- this particular docunnmt, who 

it’s from, what they’re asking for and - for me. But I know 

thatrightnowJhavcadocumntrequcstmmydeskfnnnthc 

i&pul&mtcwnscltoIthinkevayooc intheWhiteHouse 

thatlistsfournamesandaslcsforanythingmlataitothose 

four people. 

Q Okay. Andistbistbefirs-andktmbtnitit 

to the OIC. Is that the first documnt requestfromtbe 

in&pa&ntcotmselthatyouhaveheenlu&edtoIuokfer 

itcmsIistaiont.hatgtandjurysub~orhavetbcrebam 

otbrriodepcndentaunsclsub~thatyou’vchaugivcn~ 

look for docunxnts called for by the subpoena? 

A IbaveboenaskedfromtbeOfficeofIndepencknt 

counselsevaaltimcs,eithK#yandtha¶thmughthe 

white House, to look for certain documents over the las 

three, four years, bowever long this has been going on. 

Q okay. Aadtkahaveyoualsohangivendocumart 

mquests that are from tht Paula Jones civil litigation? 

A I don’t rememberifIbaveornot. Idon’trecall 

any. But, again, I’d have to think about that 

Q Okay. Going back to the fvS topic, the 

correspondence from Kathleen W&y, that, as best you 

nxa&thatrequestcamefromMr.Bennet&thatisatopic 

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Page 42 

that you dish&& from the OIC subpanas, right? In other 

wo&that’sareqtrstthatcamefrcnnA4r.Benxbe¬frcnn 

the Office of Independent Counsel subpoenas. 

A That’s CmIECt. 

Q Now,tkh4r.Bennetttopicremindsmeofoneofthc 

other privileged invocations that came up in February. 

You’ve ahxzdy talkai atxxlt your deal& with Mr. Km&U. 

If you recall, you also invoked attorney-client 

privilege with regard to a conversation you bad with Mr 

Bermett regarding Kathleen Willey. Do you recall that 

invocation? 

A Yes, I do. 

Q Okay. Is that topic, tbc conversation you bad with 

Mr.Bel&tlZI>OKRthI~WilIey,doesthathavetOClO 

with the cormqondence, or is that something sepamte? 

A That’s SaMthing separate. 

Q All right_ Tell us about that conversation with 

Mr.BmnfS. WhatwasthatconvemationwithMr.Bexmett 

about? 

A TbatconversationaskedmeifIknewiftbe 

ResidentcvasawKathlecnwilleyintheovaloffliceor--I 

&ink that’s - that’s bow I recall the conversation. 

Q Can you relate that to me one more time? I’m 

sorry, I was a little confused. 

A My recollection of the conversation that I bad witt 

March 26,1998 

Page 4: 

I Mr. Bennett was when he asked me if I had any knowledge if 

2 the Resident ~IXJW or ever saw Kathleen Willey. 

3 Q Okay. Do you recall where this conversation witl 

4 Mr. Bamctt occurred? At the White House, at home, in his 

5 office? Wkre was the conversation? 

6 A It was on tk telephone. 

7 Q Okay. Did he call you or did you call him? 

8 A No,htpagedme,actually,Itbirtkorthc 

9 opemtor, the White House operator paged me with a cal 

0 Q Okay. Can you tell us approximately wkn it wan 

I this amvasatioll cnzzcud? 

2 A It was in July of 1997. 

3 Q Asyouun&zstandit,theNewswakarticlcsndthc 

4 Drudge report regarding tht Kathleen Willey incident or 

5IcaUSznwillcyalkgations,that~Ibelim,atthe 

6 cndofJuly,firstweekofAugustof 1997,asIrecal.l. k 

7tllat8 A kithatright? 

9 Q ~thatamistcntwithyourrccdk&mor0 A No. I don’t - it’s absolutely inconsistent with 

1 anything that I know. Was there a Newsweek article las 

ZSummer? 

3 Q Allrigtn,weIl,Idon’twanttotestify. Letmc 

4 a&it&way. 

5 Doyourecall-wbatwasittbatprompted 

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lur.BametttoaskyollahoutyourknowledgeofKathlcen 

PagtM 

WiIley? WbydidMrBennettaskyouA Idon’tknow. Itbinkyou’dbavetoaskMr. 

Hennetttllat. 

Q Wbat,ifanytbing,didbesaytoyouaboutwbyk 

wanted to ask you about Kathleen Willey? 

A So&hinghrdeomeup,andIdon’tImowwkmk 

got that information, but something had - you know, k just 

said,“Doyouknowifth3Rsi&nthassrcnthiswaman? DC 

you know her? Do you know if L’s ever Sen kr?” 

Q And did it pique your curiosity? 

A I’msureitdid. 

Q What &e, if anytbing, did bc say to you about 

th&“DoyouhlowwfidhatbaPEsidentImewthiswtlmzfq’ 

or,“DocstkPmsuIenthaveanykno~ofthis~” 

or.“HadthcResickntsecnthiswuman?” Whatclstdidk 

say to you? 

A Wbatelsedidhcsaytome? Idon’t-Idon’t 

mcallwbatelsehesaidtome. 

Q Do you recall that there was .sonx publicity about 

KathkEnWillcyillthc sununerof 1997lega&lganslticIe 

written by Michael l&off of Newsweek? 

A I don’t recall the publicity about it, no. 

Q Doyourtcalltberebeingar~ypublieityat~in 

the !nmmtu of ‘97 about Kathlan willey snpposecky - ahout 

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the President supposedly having this encounter with ha, 

wktbcr thtrc was publicity in the summcrof ‘97 Kgardhg 

this allegation? 

A Idon’trecalI-again,Idon’tre<he 

publicity. I don’t recall that anybody said there was 

publicity_ 1 just don’t - I don’t recall right now. Tk 

tim.ingofaIIthis,anda.llofthedifferentkindsof 

articles really begins to blur after a while, and I can’t 

tellyouifitwastkfirsttimeIeversawanarticlewasa 

molltbagoornvclmonths~ursixmonrbr~orcightmonths 

ago. I mean, I just don’t - I don’t rememkr. 

Ikl.KJwtktMr.BmtEttc&dmtl&summCraMi 

askedmeaboutit. IdonotrecallwknIfvstkardofany 

publicity about it 

Q hyoudwhdubfr.&Imat~youwas 

prompted by tk publicity? 

A No, I don’t recall. 

Q DidyouaskMr.Bennettwhykwgntaltoknow,cu 

wofdstotktcffec~wllykwasSkingyoutkrequeations 

about Kathleen Willey? 

A I don’t believe that I asked him why. 

Q Now,youkncwMr.Bennettwasreprcscntingtbc 

President in corme&on with civil litigation e&r being 

brought by or contemplated by Paula Jones, correct? 

A That’SCOITCCi 

Page 46 

I Q It didn’t strike you as something curious or 

2 unusual or - the fact that here’s Mr. Bennett_ the 

3 Presi&mt’s private attorney, who’s reprcscating him on a 

# civil case involving allegations of sexual harassment_ ask 

5 youifyouknewwbcthathcRsidenthadbmownorhadspa 

5 Kathleen WiIley? 

1 A I don’t - again, it may have struck me as curious. 

3 If h4r. Bennett doesn’t offer it, I don’t ask it 

3 Q And as best you rec.aIl, k didn’t offer any 

1 cxplallationastowhybea&dcdtoaskyouthseq~urts. 

I A Htmighthave,butIjustdon’tmcalltkcontext 

I inwhichk-‘youknow,kframcdthisquestiou. Andk 

1 vcrymll5khavcgiwnmcsombacirgrouadbutIjust-I 

I donot renxmkrwktitwastktk-wbyksaidkwas 

5 call&,wkrek-youknow,wbatldndofinformationk 

i had or wkre he got it. 

1 Q And tk conversation was over tht telephone, 

I cclrrect? 

P A That’Scorrect. 

) Q Approximately how long did tk co11versation last? 

I A Probably fiveminutes. 

! Q What did you tell Mr. Bennett? 

I A ItoldMr.BennettthatIknewkr,andmy 

1 recollectiouis,yes,skhadseentkResi&ntintkQval 

i Office one or two times. 

PltgP March 26,1998 

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Q Did he ask you anything more than that? 

A Notthat1recal.l. 

Q Your recolbxtion is, though that this 

conversation only lasted about five minutes? 

A That’s my mcokction. 

Q Does it strike you as somewhat odd that the 

President’s private attorney, who’s representing tk 

Rsident on a sexual -t claim, would not - from 

your xcdlcction, das not pmbe you further on this topic, 

otherthamtkfacttktthePresidenthadseenkrinthe 

OvalOfficeoneortwotimes? 

A WeIl-askthatquestionagain? Doesitscunodd 

to me that he didn’t probe any far&r? 

Q Yourtestimonyish4r.Bamettaskedyeuwkthathe 

ResidentkneworkclacenKatblemWilley,andyousaid, 

~hchadseulhcroneortwotimesinthaOvalOffia. 

Andthat’stmicaUyallMr.Baethdandtbat’saUyou 

said. Am I missing somethmg? 

A No. 

Q Allright. Ifthat’sallheaskedandthat’sall 

yousai~thatdam’tsuikeyouasoddthatkwouldaak 

only that? 

A No. 

Q Okay. Whatelsedidyoutellhimothuthan-did 

youtcllhim8nythinginadditimtothefactthatthe 

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ResidenthadsunK.f&eenWilleyintkQvalOfficeoneor 

two times? 

A Not that I recall. 

Q DidkaskwkntkPresidenthadseenKathl~ 

Willey? 

A NotthatIrecall. Butkcouldhave. Ijustthat part I don’t rememberstall. Idon’trememberiflx 

said when. 

Q Didheasktkcircumstances? 

A Not-notthatIrecalI. ButitwouldbelogicaI 

tbatkmightaskthatportionofit,butIdon’t~baif 

kdid 

Q Okay. AsidefrcrmMr.FJame&ksanyoeeaskedyeu 

-youkdtbisfivemitll&amvers&nwitbA4r.BarmSt 

aboutKat!lkulwilly. Haslulyoocaskalycuwyouknow 

aboutKathla!nwil.leyarKlkrdeahngswitbtkResident? 

AndIcanexcludeyouratmmeys. 

A No,not-weIl,letme-ktmjustmakesure 

that that’s right 

Q Hasmyooe~tkrthrmyolp~cvcraskedyau 

about what you hrow about Kathleen WiIley? 

A (Nomspo=-) 

Q And I don’t maan, you know - I 

A I know what you - okay, go on. 

Q Idon’twanttobecutehere. I’mtryingtoget 

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at, did anyone interview you? Did anyonc try to gatlrr 

informaticu from you? I’m not leaving my question simply, 

did anyone ask you that specific question? 

Q YOUknoW,wC’~tIybgtOgCtattheoUthherr. 

So please don’t narrowIy constnm my question. 

A hh-frmm 

Q Has anyone ever attempted to gather information 

fromyou-othcrthanthisfiwxni.nutccallfromIvIr. 

Balnc&llasllnyoncevaancmptaltogatbezinformaticnfmn 

youaboutwhatyouknowaboutKatillcerlwillcy? 

A Well,I’mtryingtothinkaboutit,andtheportion 

ofitthatI’mtryingtothink&outis~anybodyir 

conversation they asked that. 

believe, though, have conversations 

people in the collrl&‘s Offlce. 

Q 

believe coIlvcfiati0n~ cklyl 

h4ib about 

Howlongwouldyoue&natc convamtion 

CherylMillslasted? I’mnotaskingyoutbccontentsatthis 

timc,buthowlong-Imczm,we’vetalkedwithycuinthe 

Page 

2 A hb-bIXl. 

3 Q So I’m curious how long Ms. Mills talked with you. 

4 A I don’t know. I mean, it could have been a very 

5 conversation, you know. But it - you know, maybe 15 

6 minutes, maybe. 

7 Q Certainly-wcll,15minutes. Itakeitthcn 

8 finitely no longer than an hour? 

9 A Idon’tthbkSO. 

0 Q Okay. other than Cheryl Mills talking to you for 

I kssthanhourandMr.&nnttttalkingtoyouforfive 

z minutes, has anyone else ever interviewed you or tried tc 

3 gather inform&m from you about what you know about 

4 Kathleen W&y? 

5 A IthinkI’vcspokcnwithBrutxLindseyaboutitar 

6 weti. 

7 Q Allright. Howlongwouldyou&matcMr.Lindaey 

8 talkcdwitbyouaboutwbatyoukncwaboutICathlaarWilley? 

9 A Oh, cumulatively, probably less than an hour. But, 

zo you know, that’s - I think that would be right, less than an 

21 hour. 

22 Q Anyone else besides Cheryl Mills, Bruce Lindsey, 

u andBob_? 

24 A Not that I recaI1. 

25 Q You mentioned in your answer about Bruce Lindsey 

i-l PtBgP March 26.1998 

Page 5 1 

1 that h an hour, I believe you used ti word 

2 “cumulatively.” 

3 A h,b&unm. 

4 Q Dcesthatrneaatbuewasmarethmcmeumversation 

5 with Mr. Lindsey? 

6 A Yes,itdoes. 

7 Q How many would you estimate? 

8 A I probably had more than five umuxsations, 

9 probably less than ten. 

0 Q AndC%rylMiIls,justone? 

1 A ootortwO,maybe~three,sorm+me in that range :. 

2 Q Canyoudt~usthcapproxixnatctimtfnuntoftlx : 

3 convl%atitmswithCkrylMills? Arcthmcrcccnt? Irlotbu 

4 words, Ict’s say, arc ti since January 1st of 1998, or did 

5 tlxse occur in 1997? 

6 A Ihad-probablyhad_I’vehadaconnrsationo. r 

7 twowitlrCh&Millsainccthef~oftkyear,Januxyof 

8 ‘98, I think. 

9 Q Anypriortothat? 

D A IknowIhadatleastoneconversationwithher 

1 last summer. 

2 BY MR EMIKICKz 

3 Q Anyone else present during the amxrsaticns you 

4 werejust describing? 

5 A WclI., I don’t know. I know at least two of the 

Page 5; ! 

I cccasionstlmtwereoverthete~phoneand2 Q Anyone else on the line for thosz t&phone 

3 conversations? 

I A NottImtIrccalI. AndI-lctmcjust-lctme 

5 thidc8gainaminutebecatm-whekhfzsk-atanytime 

5 didwcdiscussICathlecnWilleywhcnotherpeopkwere 

1 present 

1 MyammlcyshavebecnpKsmtinmamversation. 

J Q For - I’m sorry, for one onwamtiaa with Ckryl? 

1 A That’s as 1 d it. 

I Q So that would have been the conversation in 1998, 

! A Thattime. 

1 Q Okay. HowaboutwitbBn~~Lindsey? Wasanyone 

1 pmmutbesi&sBruccLlndseyforanyoftbeamvcrsatiars 

i you had with Bruce? 

i A NotthatIrecaU. 

r Q I’mnotgoingtogetintoanyof~substanctof 

I convasaticmswitbyouraaosncys,butinrennsoftkaamount 

1 of tim your zimmcys haYe asked you about Kathlea-l Willey, 

0 canyougiveusanapproximateamoMtoftimtbcyhavc 

1 gathxdillf~tionfKlmyourboutKnthka~ Imal& 

2 have they intcrvimrcd you for any length of time? I’m not 

3 goingtoaskyouwhatwassaid,I’mjusttalkingaboutthe 

4 amount of time. 

5 A Fifteen minutes, maybe. 

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Q Okay. Lamgobackto-sometimesIforget 

things. Onthe lzomqXmdeace from Ka&l&n Wiiey that Ml 

Bennett asked you to look for. 

A h&n-lnnm. 

Q Idon’tthinkIaskedyouwhenheaskedyoutodc 

that. You~a~~~~~~~~~of’97 

which was separate from the corrcspondena, correct? 

A b%dltml. WC& kt SIC again Chifj’. I’m not 

absolutely azrtain ht asked me, so - 

Q Okay. Asbestyouzecall,hedid 

A AsbestImca&butIcan’tevengiveyouatim 

fmme if I’m not absolutdy cuGn. I can’t reman- tk 

cotlveBation. 

Q Whatisyourbestrecollectionofwhcnitwasyou 

looked for the corrspoedence frum Kathleen Will@ Was ii 

in 1998 or 1997? 

A ItWaSitl1997. 

Q Doyouzeca&wasitinthesummer of’97orwa! 

it in late 1997, for example? 

A Ibt~evtitwasinthefall,butIcouldkway 

off on that. 

Q ~yo~~WhO,ifanyooC,yoUgavCtfr: 

3 correspondence to? 

4 A ~think~gavttbe cxnmpnbu to Bruce Limby. 

5 Q Whem did you look for the correspondena? 

Page 54 

1 A You know, I don’t even - I can’t visualize lookin 

2 for it to even how wbae I looked for it. I may have just 

3 asked my assistant, you know. 

4 Q And you may have told us before. Your assistant 

5 are? 

6 A My assistant is Rebecca Cameron. I don’t 

7 remember - I just don’t have a visual rtcollectiou of 

8 sitting then? di&xtg through filts - 

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Q Okay. 

A - in one particular place looking for this, you 

know. 

Q Take is through generally - ~fo~a~ly, the 

~~ofevidencchaM:alittlcwaytodcalwithtbingsLikt 

this. 

A h’hn-lm’nn. 

Q Take us through sort of your habit, your routine, 

your practice of wlxzre it is you would normally put 

~~~,~~~~d~pi~~~w~d 

look? 

A Well,Iwouldeithergiveittothe-totfr 

Ttcords management who kaps the presidential EXX&. I’d 

justgiveittomy-toRebeccatofdeit. And-or3 

there was a rcspcmx, it would have - well, would probably 

have gone! ?cl lrxfxds lnanagemcnt. 

Q A response, for example, if it’s from the 

March 26.1998 

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Pxesident? 

A him-lIUlID_ 

Q Okay. 

A Sometimes on personal correspondence, they file I 

intbcpTsonalcmepndcnaarta AndsoIcouldhave 

~~~~~~~~~~i~k~~~~ 

and see: if they had anything. 

Q Okay. Just so I undemand, so it sounds like 

there may be three possible areas one could look for this 

kind of conspondence. 

A Mm-hmm. 

Q biSnxordsmatmguUM 

A bf.tWhmm. 

Q Secondis-theoneyoujustmcmtioned,thcthird 

OIIC. 

A kl?ZOd COrrespOndtace. 

Q Pcrsonalcoxmspondence. 

A Mm&mm. 

Q Andthethird,youmightaskRebeccatolookfor 

it - 

A &&tmm. 

Q -Mmrcwhenelsebesi&sthosetwoplaces? 

A Yes. Shtwould--welist 

~~~~~hol~~f~f~ati~~ 

mdlhlSdS&KlIlOfflo~ manramntrathxwdd 

Page 5c 

I bcsortofaninterimhold,Ithinl&to2 Q &XsthePK&deatkapSnyftiinhis-Iike 

3 Oval Office study, dining roam, or anything like that, 

I scparattdapartfromtbcseanasyouideotified? Inot& 

5 wordqwouldtherebeaplacethatyoucouldlookinthe 

5 PIr!sibt’sspaafor~ cithcxfmmKa&bal 

7 Willey or to Kathleen W&y, for example? 

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A No. 

Q So this wouldn’t have beco - the conqondence 

~t~~f~~~~~~~‘t~~ 

looked for in the President’s Oval Office, for example. 

A mt’s correct 

Q And not in his personal study. 

A -t’s CWECL 

Q WhywasityougaveittoMr.~ Yourbest 

ncoUcctioas you gave it to Mr. Lindq. Assuming &at’s 

~whywasityougavcittoMr.Lindq,siaceyourbest 

rccolkction is h4r. Bennett asked you to look for it? 

A Again, that’s why I’m not aztain Mr. Bamctt’s tbc 

one that asked me for it. 

Q O~Y. I 

A I probably gaw: it to Mr. Lindsey because I tmsted] 

Page 53 - Page 56 
1353 

MUlti-PtlECm March 26.1998 

, Page 57 

I 

F 

1 that k would handle it appropriately and k would & it to 

2 tkriglxtpcrs5n. 

3 So-andIdon’tknowthatMr.Bennettaskedme 

4 IkeepclaSyingtkt,but-youknow,itis?hosekindsof 

5 thingsthatgo-I’mnotsurekaskcdme. Imaykvcjust 

6 l~f~~itdsaid,“Look,youhnow,thisisanissue 

7 and kre it is,” you know. 

8 Q ?%c correspondcnee that you found, approximatel] 

9 howmanypiaxsofpapuareyeuUlkingaboutthatyoufaux! 

0 whichwas &mcspondencc fmmKattlleen W&y? 

1 A Oh I don’t know. I’ve, you know, lwd all this in 

2 thepapersnccntly,andifIhavetogob~aadtfrinltd 

3 wktI’vereadintkpaperratkrtknwhatIrvarknow,it 

4 couldbetkcascthat5 Q Let’s not criticize what you mid in tk paper. 

6 A IdorA-1dorCtlCnow. 

7 Q okay. 

8 A It’s 10 or 15 pieces, maybe 20. I don’t - 

9 Q ObY. 

0 A Yeah. hdcpendcaffnmklyOfhaViIlgrradthaf, 

I I’d probably say five ore ten. But having xead thaq you 

2 know,itseemsIiketkre’smorethanthat. Iknowyoujust 

3 told no not to, but - 

4 Q No, that’s okay. 

5 A -1’maIlmixedup. 

Page 58 

Page 5’ 

1 Q Allright. IftkPresidentdidwrite 

2 corrqx&a~ce ta Kathlan Willey, what would be tk nonn~ 

3 ~of~tionintennsoftkWhiteHousemaintauunga 

4 copy? Who would maintain it? 

5 A Records management would maintain it. 

6 Q Not pasonal records? Let me stop for a minute. 

7 Thcn’sakntiattkdoor. 

8 CInterruption to procwdings.) 

9 MR BARGER: 1 guess we can continue. Mr. Ebnmick 

10 hsskftthe!room. 

II BY MR. BARGER: 

12 Q IfthcPresidenthadwrittencorreqxmdcnato 

13 Ic8tblc#xl willey, tk norxtuil cowsc of Kuxd-keeping is that 

14 a copy would be kept in records management_ aurect?’ 

15 A ‘Ihat’S m 

16 Q hesthel4esident,toyourknowledge,keepany 

17 copies himself of perXmaI conqondcnce k writes to 

18 peopk? 

19 A No. 

20 Q WhentkPresidenthandwritescomspandcnato 

21 someonc,isacopyoftkhandwrittmcomspondenastil1 

22 maintained? 

23 A Yts. 

24 Q Andwhenthel’nziidentwritescanespondenceto 

I 

I Q YOUCanquaIifyit. 

2 A Mm-hmm. 

3 Q SoIunderstandyouranswer-andIappmciate 

4 yo~~~~~~~~~~~ck~~ 

5 separate what you Iaxw versus what you read. 

6 A Mm-tmrm. 

7 Q So I understand your answer. Before you had r& 

8 this, you would e&mated that you kIieve you fomd five to 

9 ten pieces of correspondence. 

0 A I would have placed it around ten. 

I Q Okay. And in light of the newspaper ahcles or 

2 thtrmdia,th:pubficityaborrti~pcrhapsnow,asmsnyar 

3 20, but that’s rough estimate. 

4 A That’ScOmct. 

S Q Okay. Did you look for or find any comspondcncc: 

6 from tk President to Kathleen Willey? 

I A I didn’t find any, no. 

8 Q Hadyoueverbeenaskedtolookforany 

9 cormspondcnce from the Fbsident to Kathleen Wilky? 

D A Well, I don’t - I don’t know. I wouldn’t keq 

1 conrspondence from the President to Kathleen wilky. 

2 Q Thatsoundslikethzanswerisno,butletmemakc 

3 sumthen. Haveyoueverbeenaskedtolookforaay 

4 correspondence from th President to Kathleen Willey? 

5 A Not that I recall. 

I 

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1 mailitbimselforisthatsm&&gklmvestosomcbody 

2 else? 

3 A He leaves it to somebody else. 

4 Q who would k normally kavc that to? 

S A EitkrtoBcttyortomc. 

6 Q DoyourccaIliftkPresidcnthaseverhadyou 

7 mail any correspondence from him to Kathleen Willey? 

8 A Idon’trccaII. 

9 Q Is it possible he has? 

IO A It’s possible. 

I1 Q Butinyourexp&na,ifhehadwrittena 

I2 kndwrittmaotetoKadllculwtiey,tktwolddktkkind 

13 ofthingthatacopywouldstillbekeptinrecords 

14 msnagcmcnt. 

I5 A That’s co16 Q Andyourkstrecoilcctioaisnooneksevcrssked 

17 you to search for conqxmdcna from tk prtsidcnt to 

18 Kathl&n w&y. 

19 A ‘I-hat’s axnxt. 

!O Q GoingbacktothctopicIleftalittlewMeago, 

!1 otkrtkntkfi VMninute collversaticm you hsd with Mr. 

!2 BcMcqtk~two,thlE(:oTso~~youkdwith 

!3 Chayl Milla, which totakd appnxbnatcty 15 minursS, and tk 

!4 mo= b five, less than ten conversations you had with 

5 Bruce Lindsey that totaled less than an hour, and tkn last, 

Page 60 

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Page 61 

your approximately 15 minutes with your attorneys taking 

about - we’re not going to get into the substance, but 

genaally the topic of Kathleen Willey, has anyone eLse ever 

asked you about or fiftempted to gather information from you 

about what you know about Kathleen Willey? 

A Other than YOU? 

Q-thanA NotthatJd. 

Q Cumulatively, we% well topped the record. 

A Rtaily, yOU havt. 

Q okay. Gtatrally What LWE your c~m’U%tiOIlS 

with-whatdidyouandCberylMillstalkaboutwith~ 

toKatbleenW~ Whatdidyousaytobcf! Wbatdidsbc 

want to know? 

A Well, tht last conversation I had with htr was 

regarding a - I think a letter that Kathleen’s attorneys 

releasul,andshe&aim -itwasnotsolzlethingwebadin 

ourfrks,andsheaskedmeagainaboutthaL 

She said, “We& it’s not a letter that you 

~andthcy’vegot-sbe’sreleaxdalettrr.” AadI 

said, “WC& I’ve given you all evc@ling I’ve got.” 

Shejustaskedmeaboutthatandtoldmachlally 

it’s from the ocws rnapBzines thisweek. sothatwasthclast 

conversation I had with her. 

Q Okay. I apologize. I haven’t been able to - and 

I I’m.sureyouprobablybavcn’teitk-becnabletokccpup 

Page 62 

1 

2 with all the news articles -- 2 

3 A Mm&mm. 3 

4 Q- about these topics. So I understand you - 4 

5 apparently tbe&s a publisbal xcport that Kathl&a Wii’s 5 

6attomeyh~srcka~ed~ome cmrmpondena from tbc Presi&nt’ 6 

7 A No. 7 

8 Q No? 8 

9 A It’s from her t0 me. 9 

0 Q Oh, okay, it’s from Kathleen Willey to you. 0 

I A That’s currect. 1 

2 Q AndChaylMilkbasicallyaskedyouifthcyoryou 2 

3 ortlxWhiteHou.sehadacopy. 3 

4 A tit’s COIY’CCL 4 

5 Q And you said no. 5 

6 A That’s - 6 

7 Q Okay. How about yora prior umver~atio~ls with MS. 7 

8 Mills? Is that gamally the substana of the cmver~atims 8 

9 with Ms. Mills, the most recent conversation, that it 9 

o concemed this letter? 10 

1 A That was the most recent one. !I 

2 Q How about the other conversations, what did tky 12 

:3 cmcern? 13 

:4 A Well, I think one conversation was probably just 14 

Y generally in the presence of my attoxneys, generally - I5 

March 26,1998 

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Page 63 

A - general stuff. 1 mean, nothing really specific. 

And then I think that at some point last summer -- lau 

sumwrorla~f~,shejustindicatedthat--justaskedme 

if I knew anything about her. Did I think that was somtbody 

thasyouknbw-Ithinkatthattime~~sominkling 

of some publicity, wfietlxr it was out or not, but -- 

Q okay. 

A Andsbewas-raid,“Doyouknowanythk@aboUt 

her, or did the President ever su kr?” 

Q Andwhatdidyoutellher? 

A JustwhatI’vealreadysaid,tbat,ycs,Iknewha, 

and_~&haclbeenintovisit_youknow,onaortwia, 

andQ Okay. 

- that’s tht extent of what I knew about her, 

AY. 

Q And in your conversations with Brua Lindsey, 

genera@ what did those conversations with Mr. Linw 

concemorentaiI? Whatwasthatabou~witbregardto 

Kathleen Wilky? 

A IrmymkrthatOlX?oftkf%StUXlMsatiOllSWaS 

thatMr.Lindseyclkla’tsamtobca~of~sbcwaswkal 

somcofthisstuffcameup,andjustt&samcqxs&ms,doI 

knowhcrandwfioissheandthatsortofthing. 

And I think the other later conversations more had 

pagtb-- 

to do witb maybe this corrcqxmdena. I found it in stages, 

Ididn’tftnditaltatoncc,andsowhcnI’dfiadsomdhin& 

I’dIcthimlmowIhadsomthia&andhewouldunne~it. 

But that’s genemlly, I think, what - basically 

what we talked about. 

Q Okay. Lctme-IaUudedtowhatsumslik,and 

probably is, a long time ago - 

A M.ID-~I~~. 

Q -thatIwouldgothroughsomeofthis 

chronologicalIy. 

A Mm-hmm. 

Q Lctmdoalittlebitofthatnow. 

MREMMIM: CanIaskoncqlbMionMR.BARGERz Yes. 

MREMh4lM: -justsowedon’tmoveofftkisar 

too far. 

BYMREMMIM: 

Q LnyourcunvmationswithBruceLin~andwith 

Cheryl MiIls, did they take notes? 

A I have no idea. Two of the conversations with 

Cheryl were on the telephone, so I have no idea 

Q Howabouttheonesthatwereinperson? 

A I don’t think she took notes, no. Aod with Bruct, I 

he never took notes, no. I 

Page61 -Page64 
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Mub 

Page 65 

1 BY MR. BARGER: 

2 Q ~tmechroao~ogi~ygothroughsomcoftiand 

3 startbackin 1992. 

4 A bhhmm. 

5 Q h~thcsuuxuz of 1992, tkn Governor clintc0 was 

6 running for Presidenf correct? 

7 ACOlRXt. 

8 Q Anddidyw Eiccoqmyhimaloccasionin!3omcof 

9 hiScampaigning? 

0 A otidy,ywh 

1 Q Justto&rcshtkgrmdjury’srccollection,ti 

2 tlmtpoiotineIlejwllworkdforaadimdwakcdfaanumbcr 

3 ofyearsforthzgovelnorinArkansa&corIect? 

4 A That’s camcf 

5 Q AndIforgetyourexacttitkwhenyouwerein 

6 Arkansas. 

7 A YOU want mt to tell YOU? 

8 Q Pleast. 

9 A ~WSSscheduliag~. 

0 Q Okay. Andm clcaialyoumidyou~~t.he 

1 governor on SOM of his campaign stops, conect? 

2 A hh-hmm. 

3 Q Doyouncallthatthexecamatimeiu 

4 approximately the fall of 1992 that the governor attend4 a 

5 debate, I believe, in Williamsburg, Virginia? 

Page 66 

I A Yes. 

2 Q Did you accompany him - 

3 A Actually - veil, it wasn’t - tht &bate wasn’t in 

4 Wilhnsburg. 

5 Q All right. How would you - 

6 A It was the debate prep. 

7 Q The debate prep, okay. The debate actually 

8 -din-- 

9 A Richmond 

0 Q -RicbmoQd. Doyou lurmntlcr the ajIproximatc time 

I period that occumd, September, August? 

2 Q No. Itwasinthefall. Ithinkthzywere 

3 probably in October, but - 

4 Q Okay. Did you accompany him on that trip? 

5 A Ycs,Idid. 

6 Q Doyoureca&wasbchavingtroubkwithhisvoice 

7 from the hard campaigning ht was doing? 

8 A Yes, he was having trouble with his voice. 

9 Q WhenthePresidentcameforthcdebateandthe 

0 debatep~.doyoumaUwbmheamived? Didhcflyinto 

1 Richmond, for example? 

2 A IthiI&sO. 

3 Q And hm Richmond he went to Williamsburg? 

4 A Yes. ~thhkthiit’ShO~-yeah. 

5 Q And after staying in Williamsburg, came back to 

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Richmond for the actual debate. 

A Yes, that’s right. 

Q Do you recall whether after the debate there was 

a - it could be before the debate, but around that time 

period, either before or after the debate, thcrc also was a 

campnign appammce on tk grounds of tk govenor’s mansion 

in Virginia there in downtown Richmond? Do you mmzmbe~ 

that? 

A No, I don’t remember that. 

Q okay. 

A Was it af&x tht &bate, you said, or before? 

Q Idon’tknow-Idon’twanttousemy 

rec&ction - 

A h&PhIIU!L 

Q - but as best you recall, do you recall whether, 

either before the debatt or after the debate, but right in 

thttimcpaiod,hcbadac8mpaignappearance, arally. 

tb?growldsoftkgovemor ‘SIMIlSiOtltk!GillRi~? 

A Idon’t rcmembcrthat 

Q okay. ~ingbacktobisarrivalinRichmcmd,do 

youmallwbcthcrbeflcwin? 

A To Richmond? 

Q Yes, ma’am, as opposed to by train or something 

like that? 

A YCih,~thi&ycah,hefkwiu. 

Page 68 

1 Q Doyourecall- andIguessperhap.sthisisa 

2 little bit - do you how Kathleen Willey? 

3 A Yes, I do. 

4 Q And have hewn bzr for a number of years. 

5 A YeS,IhavC. 

6 Q And after Presidcat Clinton was elected in Novembm 

7 of’92andtookofIiceinJanuaryof’92,thaecameatime 

8 whenKathkmWiIleybacamaWhitcHouocvolunkqcm&? 

9 A YcS,ub-huh 

0 Q DoyourecallwfmitwasthatyoufirstmetMrs. 

1 Wii Doyourccallwhcthcritwasaftcrsbebcuunca 

2 White House volunbxr or whehr it was then Govemor 

3 Clinton’s campaign? 

4 A IthinkImetberduringthecampaign,butI 

5 wouldn’tbetmylifeonit 

6 Q Okay. How many times would you e&mate you 

7 accompaniatGovamf Clintmmamp+.ntripswkrckfkw 

8 during that 1992 campaign? And you can give a range. 

9 A It wasn’t vexy many of t&n. I would say five or 

0 so. 

!I Q OnanyofthostcampaignstopswithtbenGmmnor 

!2 clinton,wuethcTeevcranyoccasionswbcrebc~youto 

3 obtain phone n&xrs of any of the people he saw, tk people 

14 htwasgratin~orpeopkthathtcamcincontactwith? 

!5 A I don’t recall. 

Page 65 - Page 68 
1356 

Page 69 

1 Q Whmyousayyoudon’tnxal&youdon’traaUhim 

2 doing that or - 

3 A 1don’treaUhincvcraskingmcmgetsume~’s 

4 - anybody’s phone number. 

5 Q Okay. Doyourccall-andktmebcmore 

6 specific. Doyourccallwhcthcrhecvaaskedyoutoga 

7 Kathlexm willey% phonenumber? 

8 A Well,Idon’trccallthathecvcraskedwtogeta 

9 phone number. 

0 Q Have you heard news sports or allegations that he 

1 askedyoutodothat? 

2 A ~haVIZD’tlCadi3llyDCWSrrportthiSthcashdBlCtIY 

3 do that, no. 

4 Q Okay. And your best recollection is that ht did 

5 not? 

6 A Ijustdm’t rlanzmkroocwayortkotha~ 

7 k-ye&my8 Q Okay. 

9 A You asked me spazif~cally, did lo or didn’t lx? I 

:o justdon’trccallthatk:evcra&dmetogetanybody’s 

:1 phonenumber. 

2 Q Okay. 

‘3 A And so, specifically, that would fall into that 

4 c2egory. 

.5 Q Okay. And you savedme the next question. That 

Page 70 

1 was - not only Kathlan W&y’s, but your b& rcc~llath 

2 is, he never asked you to get anybody’s telephone number. 

3 A That’s my best recollection. 

4 Q Haveyousxnan~cnewsreportabouthiscsmp&n 

5 sKTpinRichm~~LiilmMtciovemorBeyer-&pu 

6 know who Lieutenant Governor Beyer is? 

7 A Uh-huh, I do. 

8 Q Have you seen tk videotape where Lieutenant 

9 GovanorBeyerisontbesaccn,andtkPresident’stalkirrg 

o tohim,andLicutenantGovcmorBeyeraudKatMccnWillcy’r 

1 name is mentioned? 

2 A Idon’t’thinkIhavc. 

3 Q Okay. Ixtmsawchavctbat. I’dliketoshow 

4 it to you. It may help nfresh your mm~ry. 

5 w the videotape identified above was 

6 &own to tht Grand Jury.) 

7 BY MR. BARGERz 

8 Q Myquestionis,having-and,bytheway,you 

9 rccogn& yourself over there on the left-hand side? 

!O A uh-huh, I do. 

!I Q Allright. Andthepersoninthemiddleis 

2 Lieutiant Governor Beyer? 

3 A uh-huh. 

14 Q ~thathe~pti~inrCfI’eShiDgyOUrIDCmOry 

15 w&her the President asked you to get Mrs. Wiucy’s pborr 

, 

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llumkr? 

A No, it doesn’t. I 

Q Is it possible you did? 

A It’s possible. I just don’t xmember. 

Q Do you recall any conversation with the President 

about K.&an Willey? And I’m talking about here at the 

~kportin’92. Doyauradlanyconvasationwi~ 

@e Resident about Kathlm Willey or - and let me be clear 

hz. He may not have used the name, but he may have 

dinxtedyoutogoget somaxx’s phone number. 

Doyouruxllhimdoinganyth.inglikcthat? 

A Formtogogusox&ody’sphonenumbu? Idon’t 

rccaUanytimetbatkaskalmetogogctsom&ody’splxme 

munbcr. 

Q But it is possibk? 

A It is possible. 

Q Okay. Andyoudon’tnxallhimcvcrdoingthat~ 

anyoftbeotbucampa@ stops? Inothcrwo&+youdoa’t 

rccaUanyinstanccwkrekaskcdynutogogetsomebody’s 

phone number. While you say, “Well, perhaps it is possible 

hthadmedothat.” 

A Mm-hmm 

Q “Idun’trecallanytimchehadmcdothat_” 

A Yeab,ktmjust-ktmthinlcbackominutc. 

Q Okay. 

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A Because I didn’t go on vexy many places, but, you 

know, it a&nly is - I know I’ve got to isolate that time 

asopposedtoanytinzsinccthcn. l-l&sQ fight. Andifithelpsatall,wccanlimititto 

the 1992 campaign. 

A Yeah, I kuow that’s, you know, basically what 

you’m afta, and I Qn’t remmber 8ay specific istance that 

kaskedmetodoit. It’spossiblc,butIdoa’t-kra 

timcheaskcdmtodoit. 

Q Okay. Lctmesbowyouanotbcrclipandsccifthat 

may help you as wclL 

(whtrcupan, a portion of the videotape idcntifiid 

above was played for the Grand Juay.) 

BY MR. BAROER: 

Q Havinglookdatthattapc,docsthatappcartobc 

apoltiooofthcanrreti~ofthcPrcsideoSthmClinton. in R&non& but fium a diffmt angle? 

A Yes. 

Q Andonthis_~dvideotapc,arcdidalongcrand 

clearer picture of your presence, correct? 

A h&l-hmm. 

Q Anddocsitappearthattkseccmdvideotapcals 

Lieutenant Govcmor Bcyerinthtpictuxeaswcllwitb 

Governor Clinton? I 

AUh-huh. 1 

Page 69 - Page 72 
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Page! 73 

Q And from this vidcotapc, does it appear that 

GovcroorCLintooistalkingtoyouaadtbzndirstingyou~ 

dosomthing? 

A That’s right 

Q Havinglookexlatthat,doesthatzrfrcshyour 

KcoIlaziooesto~Govanor cl.intoasskadyoutogo 

get Kathleen will& tclcphone mmkr? 

A No, it doesn’t 

Q And,again,isitpossiblchehadyoutodothat? 

A Yes, it is possible. 

MRBARGERz -fhiSiSaS&Odapl~~SlI~- 

1thinkm’nckmcfathcday. My& ‘. &isthatMs. 

I-kndchis tschaudtoooMbackal~~. 

So,MzuiamForcman,maythewimtssbccxcuscd: 

TEzFtxEPERgo~ Yes,shomay. ThanlcyouvaJ 

much. 

MRBAR- nankyouvaymuch Wc’lIKcyouoa 

‘fucsday. 

T?EwrnEs!k okay. 

(llle witness was excused.) 

(whereupon_ at 4:30 p.m., the taking of the 

tc&looyilltheprcsencc ofaN1quorumoftkGraadJury 

was amcludcd) 

*+*a* 

Page”* March 26,1998 

Page 73 - Page 73 
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“‘NITED STATSS DISTRICI CO”RT 

ror TNC DISTRICT or CoLlmsIA 

I” a?,: 

GMJID JVRX PWCXLDIWGS : 

_-____--_---_-s--x 

GrLnd Jury - lo. 3 

Unit8d St.Z.s Di,t+ict Co"rc 

101 th. Dlstrlct of Col"mbia 

3rd ‘ consriruuoA, Y.Y. 

Wuhinqton, D.C. 20001 

T".,d.y, ,4.rch 31, 1999 

Tha ustlrony or NANCY GxGGwzIC" 1.s ut*n in the 

BY MR. BARGER: 

Good morning. 

Good morning. 

l4arch 29. 1997, ccmuacinq .f 9:S7 ..m., ktorr: 

DAVIDHxCMcL#(ICx 

SDUm,UISZWG 

A8,ocI.U xndepndmt Counsel 

Ottice Of xnd.pnd.nt couns*1 

1001 rwmmy1vmia Av*nw, W.Y. 

suite 49GYOJxh 

IlashlnqCm, D.C. 20004 

Multi-Page r*I March 31, 1998 

Page 3 

1 PROCEEDINGS 

2 whe=upon, 

3 NANCY HERNREICH 

4 was called as a witness and, having been first duly sworn by 

5 the Forperson of the Grand Jury, was examined and testified 

6 as follows: 

7 ESkMlNATION 

8 

9 

1 IO 

I I1 

1 I2 

1 13 

1 I4 before the grand jury, correct? 

1 ,5 A YCS, Ihave. 

1 16 Q hfact,~behveyoutestifiihstThursday 

1 ,7 afternoon, and in or&r to try to complete your testimony, we 

1 !8 had you come back today, wrrect? 

I 9 ACoIXXt. 

1 !O Q m right, thank you. 

1 !l l’dliketogooverjustafewoftheareasina 

i !2 little bit more detail that we covered on Thursday and cover 

1 !3 somenewareas. BeforeIsta&justtogiveyouti 

2 !4 oppoxtunity, is there anything since you testified last 

1 !5 Thursday that has come to mind, or that you’ve recalled 

2 

Could you please state your name for the xtxord? 

My name is Nancy Hemreich. 

And, Ms. Hemreich, you have previously appeare 

mq. ; 

CONTENTS 

Page 1 

2 YITNESS: Page 

3 ".ncy Hamreich 3 

4 

5 GRAND JURY EXHIBITS: 

6 Ye. NH-1 Dr."lnG 117 

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differently than you testified to last Thursday? 

I know you gave us your best recolkxtion of 

things, but just to give you the opportunity, is the 

anything that’s come to mind since that you need to qualify 

any of your answers? 

A The only thing I can think of is that -- you had 

askedmeaboutwhetherIhadad ocumentrequ&,butIalso 

had one on Monica L.ewinsb earlier that I’d forgotten t 

mention last week. 

Q Okay. Thank you. 

I don’t think I will cover that in any detail, 

although Mr. Emmick may, but just to give us a time frame, 

when, as best you recall, was the document request regarding 

Monica Lcwinsky? 

A Well, obviously, it‘s been since, you know, January 

21% so - 

Q-fight. 

A So I can’t tell you precisely. 

Q All right. ‘Ihis was a document request from whom? 

A I think it was hXkp?ndent counsel, Office of 

Independent Counsel 

Q Speaking of document requests, that’s one of the 

topics I wanted to cover with you., so it’s just sort of 

genemlly the topic of records, and you testified briefly in 

response to some of my questions I asked you last week abou 

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colTespondence. 

Page ! 

As I understand it, as I recall, generally there is 

a records-keeping function for pcmmal corresponclena at the 

White House; is that cmrect? 

A We& the= could be several -- several ways to 

describe that. We have a department called Personal 

Correspondence, and generally on replies to personal 

cc3lllSpondalcztho5cgototkmccofRccurds~t. 

If there’s a reply that goes out to a personal later, then 

all those things go to Records Management 

Q All right. 

A Andtheninsomeofthcothtrcorrtspoadencepersonal currtqondence is listed on pieces of paper, an< 

tbosecvaltuallywillgoto,you~,~~tas 

well. 

Andthen--tbenImakea&&minaticmoasome,cm 

personal correspondence sort of as an interim nmsmment 

untilIcanmakeadecisianonwhattodowithitfmally,to 

file some personal letters until the time is that I can go 

through it and then, you know, send it to Records hbagunmt. 

And I just happen to file those in tk Personal 

C0~pondaiccarrca&ausctlqb8vemoreroumtudoitthaa 

I do, they’ve got more space. 

Q The Personal Correspondence area to which you 

refer, generally where is that located? Is that somewhen 

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I every six months, but -- 

2 And then sometklts I just throw them away. If it 

3 doesn’t have a lot of meaning to me and it’s not, you know - 

4 tbenIjustputitmtbetrashcan. 

5 Q Okay. so correspondence to you that’s addrtssed to 

that has some proximity to your offlice, or is that somewhere 

else? 

A It’s in the East Wing. 

Q Let me use an example to flesh this out and perhaps 

clarify. For example, if there is a personal letter to you, 

or a Ietter addressed to you, gamalIy what would happen to 

that letter wlxzn it comes into the White House? Sort of take 

us through. Would it come to you, and then would you filt 

it, or what would -- take us through that. 

Q I think various things would happen. If a personal 

letter - if it’s personal and has some meaning to me, then I 

would save it personally. For instance, it was a really 

nice, for instance, thank-you note or something really 

special about it, then -- then I would just save it. You 

know, I’d just put it in a bag in tht office, and at which 

time I’d kind of go through it, but I would - I wouldn’t 

have particularly any ftig system for it particularly. 

AndtbensometimesIwouldgivethemtomy 

assistant, you know, just as a matter of, you know, “Here’s - 

- this is your filii” and which she probably gets to about 

llivnsificd Rmmtin~ Services. Inc. f202)296-2929 

Pagem March 31,1998 1 

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you in ywr personal capacity at the White House, “Nancy 

Hemreich at the White House,” for example -- l 

A Mm-hmm. 

Q - that letter would come to you, and you could 

then make a decision as you’ve outlined whether it’s 

something that would be filed in the official White House 

record-keeping system, or whether it would be simply 

some&iq you would keq personally, or tither it would tx 

simply something that you might just throw away. 

A Mm-bmm. 

Q Genemlly have I sort of outlined the 

possibilities? 

A hat’s eornxt, mm-hmm. 

Q With regard to Kathleen Willey, did you ever 

m&e any camspondenot from Kathleen Wihy that yw 

lecall? 

A Well, I know I have, and I’m trying to even sit 

tllem and recall specifically which otlts, you know, I had$ 

because I had found those recently, and there have been 

articlesiathepaperaboutthem,but-soIhaverecci~ 

correspondence from Kathleen Willey. 

Q Okay. Generally where did you file the 

cormsp&mccfnnnKauhbenWii? Howdidyouhmdbtlmt 

correspoadence? Is that something you kept pmonally at 

yourdeskor!Kmewha elsc,erwasitsom&ingthatwent 

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into the White House record-keeping system? 

A You know, I don’t remember w&re it was filtd, and 

I have absolutely no mall about where we even found any of 

those. 

Q Well, you used the words, “we found,” and I think 

you used the word “mcently.” Can you elaborate on tbat aad 

what you mean by that? 

; 

Itakeit,tihasrecentiy~the 

opportuniq to look for correspondent from Kathleen Willey 

to you? 

: 

A Well, I don’t know why I said ‘9ecently.” I man, 

maybe I meant in the last six or eight months. But my 

assistant has as she would run across things, because sbt 

knew I was looking for things. So in her f&ng, getting 

mady,forinstance,tesendthingsteRecordsMamagemcat,if 

she found somethmg, then she would bring it to me. 

Q Now,youtestifiedlastweekaboutamquest,at 

leastasbestyourccall,fromMr.&rmctttolookfor 

correspondence relating to Kathleen Willey. 

And I wanted to make sure whether, when we’re 

talkingabout-todaywbcnwe’retaucingaboutlefrersor 

coI?espon&nce that Kat.bleen w&y wrou? to you as OJTpos 

to Preaidctlt Clinton, whether we’re talking f&out d.ifkat 

times or different instances of looking for records or I 

wbetber the looking for the Kathleen Wiey emcsponbce atJ 

Pages-Page8 
1361 

. MllltwPSUP lu MI.rrh 71 

a..-- - WV A-a-VU 21, a//v 

Page 9 Page 

I the request of Mr. Bennett would have included and did 1 ma& a big point to me about looking for this corresponclenc 

2 include correspondence that she addressed to you. 2 BY MR. WXSENBERG: 

3 Does that make sense? 3 Q Why would you take it upon yourself to look for 

4 A Yeah, I think what you’re asking me is whetlzr 4 Kathleen WiIley correspondence? 

5 someotm- as I said the other day, I couldn’t tell you 5 A Because it had become an issue. Somehow or 

6 definitively that it was Mr. Bennett who asked me to look for 6 another, it was up on the radar screen, so to speak. An 

7 the eorrespoodenee, or if k ever did spacifcally. And so, 7 so-andIwaotedtokak&oftkgame. Ithought,well, 

8 therefore, I couldn’t really tell you, because I can’t xecaB 8 sameooe’sgoingtoaskmeforthissometiae,some-you 

9 tbat,wbetkrksaldtolookforalleorrespondenatotk 9 know, someplace, and I should just start looking for it now 

0 President or correspondence to me. 10 andseewhattbefaetsofthis-someonewillaskmewhat 

1 AsI-IbavetbisrecoIIectiontbatIbasic&y 11 thcfactswcreatsomcpoint,andsoIshouldstartlooking 

2 t0oktbisuponmyslftodo. kmaybavekcnatsamt 12 for this eom!SJxmdence, because I rememberedthatshehad 

3 pointaconvasationwithMr.&mrettthatIwasgoingto& 13 written. 

4 tbat,butIbaveaproblemwitb&aracteri>hatkasked 14 Q IsthereanyothertimeinyourlifeintheWhite 

5 metodoit Istillhaveaproblemwiththa~beeauseI 15 House when you’ve taken it upon yourself to look for 

6 don’t xecd that. 16 correspondence to and from a particular person? 

7 Tkn - but generally wkn I started looking, I 17 A I think probably thnc have been those occasions, 

8 looked for all cormspon&ncc. And it WBs, you know, over a 18 but I can’t speeifieally tell you tight now what tbey were. 

9 period of tinx. I didn’t one day sit down and go through 19 But if I thought about it enough, I could probably come up 

10 everytb&Ibadlooklngforit. Ithinlcitjusteameabout 20 with some. 

11 over a period of time 21 MR. WISENBERG: Pardon me for interrupting. 

12 Q Perhaps I misundastood you last week, but do you 22 MR. BARGER: No, that’s all right. 

3 recalI t&fying, at least in essence, that your best 23 BY MR. BARGER: 

‘4 recollection is that Mr. Bennett asked you to look for 24 Q Well, let’s go down this road a little further. 

:5 correspondence relating to Kathleen Willey? 25 A Okay. 

Page 10 Page 1

1 A Well, that was your words and not mine. You had 1 Q 1 believe your testimony last week was, your best 

2 said, you know, “We& to the best of your recollection.” 2 recollection was that you gave tkse documen tst.oBillo 

3 I - I mean, I still have problems - I want you - 1 want to 3 Lindsey; is that correct? 

4 kveryclearthatIkveproblcmswiththafinsayingthat 4 A That’s correct. 

5 Mr. Ekntxtt asked me to look for that. 5 Q Okay. Following up on Mr. Wise&erg’s qtxstions, 

6 I mean, my best nxoIJection is that I basically 6 bow many otkr individuals in addition to Kathbxm Willey 

7 tookituponmyself’. ImaybavementionedtoMr.Benncttat 7 havtyougthacddocumcntsfartbatyouauncdovrrtoBruct 

8 some point that I was going to look for it, but I really have 8 Lindscythatrelatetotkmattcrsur&rtkjurisdictiooof 

9 problems with characterizing it precisely like that. 9 the of&e of the Independent Counsel? 

0 Q Okay. Perhaps I simply misunderstood you. 10 Does that make sense? 

1 A hh&TUn. 11 A I understand what you’re asking. Mayk you could 

2 Q Do you recall testifying that your best 12 give me some examples so I can think of something. 

3 recollection was Mr. Bennett asked you to look for that? 13 Q Anybody besides Kathleen Willey whose 

4 A Well, I recall that you said to me, “Well, to your 14 eormspoadmceyouwultaadiluatalfor,wherbcrollyourowa 

5 best recollection.” _ 15 initiative or whether perhaps at the suggestion or after 

6 QU@. 16 discussion with Mr. Bennett? I mean -- 

7 A Yeah. And to my kst recoll&ion, k may have - 17 A hfr.-? 

8 kmayhaveaskedmetodothat. Iwanttokreallyvery 18 Q Istkreanybodyelse’scorxspondenceyougatkred 

9 clear, though. I don’t recall it. And that’s what I have to 19 besides Kathleen Willey’s that you recall that somehow 

D tell you, is that I don’t recall why I looked for the 20 relates to this investigation? 

1 correspondence. 21 MR. WISENBERG: Just a point of clarification. 

2 My best recollection is that I took it upon myself. 22 THE WlTNE!S: h-hmm. 

3 My best rtcollccticm is that I may have had a conversation 23 MR. WISENBERG: This investigation and/or tk Paula 

4 somckw,somewkn with Mr. BaWS about this cornspondcna 24 Jones case, Jones v. Clinton also. 

5 that I was looking for, but I don’t recall that Mr. Bennett 25 MR. BARGER: 1’11 rephrase my question to make it a 
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larger universe. 

BY MR. BARGER: 

Page 13 

Q In addition to Kathleen Willey, what other 

individual’s correspondence have you gathered and given to 

Bruce Lindsey? 

A I don’t recall that I’ve given other people’s 

correspondence to Bruce Lindsey. 

Q Okay. So your best recollection is, Ms. Willey is 

the only instance. 

A To my best recollection. 

Q Okay. 

A But when I say that, I want to be clear that I’m 

not definitive about it_ 

Q Okay. Now, let’s assume for a minute that you took 

it upon yourself to look for Ms. Willey’s corxespondcnct. As 

I understood your testimony last we& this co~ondence 

waswithinthccustodyandcontrolofthcOfficcofRecords 

Management, correct? 

A No, not at the time I don’t believe. 

Q Okay, well, maybe I misunderstood you last week 

Where were these letters and comspondcnoe that you found? 

A I - and I’ve testified today to that, too. It 

came out over a period of time. I had my assistant look for 

those. I don’t recallwhere I found them. 

She - I remembcrshewasgoingthroughherthings 

Multi-Pagem March 31, 1998 

1 

, Pqc 15 

1 Q AU right. So that takes care of documemts thx 

2 Rebecca Cameron had within her control. I take it there 

3 wereotherdocumen ts you found that were not at the OfEce 

4 Records Management that were within your control. 

5 A I think so. I do not remember where I found these 

6 documents. I just don’t remember. 

7 Q Where would they have been? Since you’ve said 

8 they’re not at the Office of Records Management, and uc’re 

9 nottalkingaboutthingsinRebeCCaC%mm0n’s~tf0~w%eR. 

1 0 would they have bezn? 

1 1 A Idon’t know. They would have been maybe in a box 

1 .2 for her to pick up, things for her to look through. I may 

I 3 have gone through those. I don’t - I do not Xmembcr w* 

1 4 I found these particular letters. 

I 5 Q All right. But my question is -- let’s talk about 

1 6 the universe of wkze they could physicaUy be. Could tbcy 

1 7 be in the President’s - in the Oval Office, for example? 

1 8 A I don’t believe they would have. No, they could 

1 9 notbeinthcOvalOfGce. 

. 2 !O Q Could they have been in the private study? 

2 !I A No, they would not have been in the private study. 

2 I2 Q Wouldtheyhavebeeninthediningroom? 

2 13 A No,theywouldnothavebecninthcdiningrwm. 

2 14 Q Sotheywouldhavcbccacithninyouroffiaor2 I5 how about Betty me’s - would they have been in Betty 

Page 1\ 

1 Currie’s office? 

2 A No, they would not have been in Betty Currie’s 

3 office. 

4 Q So the only place - maybe I’m missing somethin 

5 but the only place they would be then is in your offict. 

6 A My offke, Rebecca’s offkc, Records Managcmnt 

7 Q You previously said they weren’t at Records 

8 Management. 

9 A IsaidIdidn’t-well,Ithinkt.hexehavebcen1 o they have found some subsequently there. I did not look at 

1 J Records Management that I recall. 

1 2 AndtheycouldhavebeenfdedinPersonal 

1; 3 &respondence. ButIdonotnzcaLla&inganyoneowz&re 

11 o tolook. Idonotrecalllookingmyselfoverthere. 

1: 5 ButasIminterimmeasureuntilthcy-wehada 

li 6 chanatogo@wghthan,thcymayhavebeenfilcdtben. 

1’ 7 Q Is~C0~dcnctdifferentthanti 

II B Office of Records Management? 

J! 3 A Yes. 

2( 3 Q Whoisinch&eofkrson~&spcm&nce? \%o’s 

2. I in charge of record-keeping in Personal Corresponckncr’ 

2: 2 A That’s my - part of my offia. Personal 

2: 

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Page 14 

1 in one particular case, getting Rudy to send them to Records 

2 Management, her filing, and she found, I think, two of these 

3 documents minimally at that time. 

4 She-yeah,Ithink-andthiswasoverthreeor 

5 fourmonths,becausetherewasn’tanyprcsstofmdthcse 

6 from anybody at the time. That’s my recokction, over two 

7 orthreemonths. 

8 Q All right. So your -- I’m sorry, you told us 

9 previously your assistant’s name, but I’ve forgotten. 

IO A Rebecca Cameron. 

,J Q All right. So RebeccaCameron, at your 

.Z instructions, looked through her things and found a couple - 

3 perhaps a couple of Kathleen Wiiey-related conesponcknce. 

4 A Well, you said at my instruction. I’m not 

5 absolutely certain it ivas at my instruction. 

6 Q At whose instruction would it be? 

7 A I’m not suxtz it was at anybody’s ins&u&m. 

8 Q So 8~t you saying that she on her own is just 

9 happening to look for Kathleen Willey documents? 

0 A She may have known that I had been looking for some 

1 andyouIcnow,onherawnfoundthanandbraughttbcmtomy 

2 attention. 

3 Q How would she know you were looking for them? 

4 A I may have indicated to her that I was looking. I 

s don’t -- I don’t recall. 

5 correspondena is part of the oval Office operatim. 

I Q And who works under you in that capacity? 

5 A I have four CrX@~yCCs tke. 

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1 Q Whoarethey? 1 Q You’ve already excluded - they’re not in the Oval ! 

2 A Well, now it’s Ann McCoy, Helen Robinson. Eugenic 2 Office, the dining room -- 

3 BasiIko, and MiUie Ahton. 3 A That’s ~~neCt. 

4 Q And when you say “now, ” ti else in addition to 4 Q - the study. And they’re not - your best 

5 those people worked there starting in, say, July of ‘97? 5 recollection is they weren’t in Personal Correspondence 

6 A In July of ‘97, Maureen Lewis was there, and 6 because you didn’t ask anybody to look for those. 

7 Eugenic BasiIko started in August, and Maureen left - 7 A I said to my best recollection, I didn’t - I don’t 

8 Q IsMaureentheonlyother-is&e&only 8 remember that I asked anybody there to look. 

9 addition? In other words - 9 Q Everything I ask you is always to the best of your 

0 A No. IO knowledge and belief. 

1 Q -ifwewentbacktoJulyandcameforwardwho 11 A Yeah. Well, I want to be clear that -- 

2 are the universe of people that worked under your control in 12 Q So is it fair to say that the likely Ioeation of 

3 Personal Correspondence? 13 these documents, as I think you just said, is in Rebecca 

4 A Carolyn Huber was there and left in February, I 14 Cameron’s office or in your office. 

s think, and Ann McCoy took her position. 15 A That would be - yes. That’s the best of my 

6 Q Where physically are the records located in 16 recohCt.icm. 

7 anal &rrespondam? I nxan, wkrc would ooc go to find 17 Q Do you recall whether you found any correspondence 

8 the Of&x of Personal Cormzspondence? 18 from Kathleen Willey to you? 

9 A They would go to the East Wing. 19 A I don’t recall whether I found it. 

:0 Q And do you recall whether you gave anyone any 20 Q Do you recall Kathleen Willey having written to you 

,I instructions in Personal Correslxmdemce to look for Kathleen 21 in the past? 

:2 Willey-related correspondence? 22 A Yes,Idorecallthatshewrotemeinthepast. 

I3 A Idonotmcall,otherthanthisweek,becausewe 23 Q Did you generally save that correspondence or die 

14 have document requests right now, asking anybody to do that. 24 you throw it out? 

!5 Q But prior to the Office of Independent Counsel 25 A Idon’tnznemberwbatIdidwithtbeconnspondence 

Page 18 Page 2t 

1 document requests or subpoenas, you bad not, to the best of 1 asarule. 

2 your recollection, asked anyone in Pmonal Cmespondence to 2 Q What would have been your usuaI practice? 

3 look for Kathleen Willey-related documents. 3 A Throw it away. 

4 A 1 just - I do not remember. 4 Q Wh Kathleen Willey wrote a note or a letter to 

5 Q Did you ask anyone in the Office of Records 5 President Clinton - well, strike that. From your 

6 Management to look for Kathleen Willey-related 6 recollection from seeing the documents, is it correct to say 

7 m-respondence? 7 that Kathleen Willey on occasion wrote some letters or 

8 A I don’t think so, but I cannot say that 8 correspondence to the President? 

9 definitively. 9 A Yes, she did write some letters to the President. 

0 Q So what is your best recollection - aside from the 10 Q When those would come in, generally, what woulc 

1 docunmts found by Rcbccca Cammn, your best mcolkction is 11 happentothose? WouldthosebegiveotothePnxident,or 

2 that the other documents you found that related -- the other 12 wouldthcybe~-stoppcdandwuldhenotbcbotberodwith 

3 Kathleen Willey correspondence was found where? 13 those kinds of things? 

4 A I don’t remember. 14 A Well, a combination of things. I would sometime! 

5 Q In your office? 15 listitjustonacorrtspondcnctlist,sometimtsIwouldshow 

6 A I--1don’trememberwhertIfoundifandthat’s 16 ittohim,andsomehzsIwouldsenditofftohavcareply 

7 allIcantellyou. Ihavenovisualrccolla%ionofwbex1 17 done to it. 

8 looked for it, where I found it. It could have been - it 18 Q Whogenerallytookcareofthereplies? Isthatin 

9 could have been in my office, it could have been Rebecca’s 19 the Personal Correspondence section? 

D office, but I just don’t remember. And I don’t want to 20 A Yes, it is.. 

1 characteb something that I don’t remember. 21 Q And if a reply is done, would a copy of the letter 

2 Q ti right. 22 bekeptinPemmalCorrespondence? Inotherwords,ifa 

3 A And I haven’t asked anybody. I could go back and 23 letter comes in, and you make a detmnination that Personal 

4 say, “Well, did I do this?” And you cm do the same. But I 24 Comspon&n~~ should do a reply, I take it you send Personal 

5 just don’t remember. 25 Correspondence the letter that Kathleen WiIley wrote. 

_- - _^ 

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

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A Generally, no. 

Page 21 

Q Generally, no, what? 

A No letters of that sort would be kept in Personal 

Correspondence. 

Q what would Personal Correspondence do with the 

incoming letter after they wrote a reply? 

A After the President signed the reply,.it would go 

to Records Management. 

Q Okay. And how about a copy of the reply that was 

w&ten, what would happai to that? Would a copy be made? 

A Acopywouldhemade,andthatwouldgotoRaxrds 

Management. 

Q It is correct, iS it not, that replies to some of 

Kathleen Willey’s eorrespondenee were made? 

A I believe that there were some replies made. 

Q Doyourecallwhetherthesewererepliesthatthe 

Presideuthimselfwro~orwhetbertbeywerempliestbat 

Personal Correspondence wrote, or both? 

A I think they were just replies that Personal 

ColTespondence wrote. 

Q Al] right. As you previously mentioned, if 

Personal Correspondence were to mply, then a copy of the 

reply would go to Office of Records Management, correct? 

A That’s correct. 

Q And I may have misunderstood you earlier, but I 

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thought your testimony was that when you were looking for 

Kathleen Willey-related correspondence, you do not nxall 

asking Office of Records Managemen tto look for any such 

documents. 

A Again, you know, I - I told you what I - that I 

took this upon myself, as I recall, and there wasn’t a 

concerted effort on my part to look for this at Records 

Management. I was just looking for things, and I didn’t -- 

you know, if the attorneys wanted that, then they would take 

that upon themselves to ask Records Management for that. 

Q Well, when you say you took it upon yourself, are 

you now saying that Mr. Bcnnca bad absolutely no rok in you 

looking for this eormspondenee? 

A Mr. Barger, I told you I don’t recah that. 1 have 

the sense that I took it upon myself. I may have had a 

conversation with him about it. I don’t know that be ma& a 

big point of directing me to look for alI of the 

correspondence. I just don’t remember. 

Q All right. Then why did you give it to Bruce 

Lindsey? 

A Because I thought he was the best person to handle 

it. He was in the Counsel’s Office, and that he is an 

attorney and he would know how to handle it. 

Q He would know how to handle what? I mean, what was 

“it” that needed a lawyer in the Whiti House Counsel’s Office 

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to handle Kathleen WiIley correspondence? 

A Well, I’m not an attorney, and this -- 

Q Sometimes I wish I wasn’t 

A Well,mostofthetimeIwishIwasanymore,butyou know, I, frankly -- it seemed to be a - a possible 

issue, and I just thought that the Counszl’s Office would he 

inabetterpositioninmakingadecisiononhowtohandle 

it. 

Q You mentioned a correspondence list. In addition 

tokccpillgcclpicsof cormqmdcnce and copies of replies, I 

take it, that a list is made of incoming correspondence? 

A only that which 1 de&n&e doesn’t need a reply. 

Q If a reply is made, a copy of the reply is kept. 

A That’s correct, in Records Management 

Q Whznareplyismade,isthzealsoaiistmadeof 

the replies? 

A Alistmadeofthereplies? 

Q In other words, you said there’s a correspondence 

IistA Oh, I see what you’re saying. 

Q - anil the correspondence list applies to tilings to 

which there is not a nply? I misunderstood. 

A Weh,youkuow,wbentbek9terseomein,tbenIgo 

throughtbtm,~~ gasthmughthcmwithmc,andI 

decide - if it’s a thank-you letter or if it’s just a 

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courtesy letter, you don’t need to do a thank-you - the 

President doesn’t need to do a thank-you for a thank-you. 

Sothosek.indsoflettersIusualIyjusthavethem 

listed. And if there’s not - you know, if it’s a courtesy 

of some sort or if it’s not an issue or doesn’t really 

requireareply,thenIaskthatitbe-thatitjustbe 

listed. And then the President is given this list. 

Q Is a list made of things that are replied to as 

well,ordcesthecoricspondcncclistumsistofcmlythosc 

things them is no reply? 

A Well, it is - the eo~pondence List is that list 

which-thosethingswhichldctcnnincdonotnccda~ly 

onrbefrcmtend 

Q Okay. Andwhomakesthe umespondenalist? Who 

types that or writes that out? 

A Tberebavebeenvariouspeoplewbobavemadeit 

overaperiodoftime. 

Q Let’s go back to - let’s start now and work our 

way back and I’ll tell you when to stop. 

A Okay. I think Millie AIston does it now. And I 

have probably had various interns work on those. I don’t 

know if either of my assistants have done, but I woulc 

imaginetbateitberKellycrawfordorRe~C%meKmhas . 

done&cm. AndIthinkRettyCurriedidtbunearlyinthe 

administration. 

c 

Page 21- Page 24 
1365 

Multi-Page- March 31,1998 

Page 25 Page 2’ 

1 And &II our lists weren’t strictly those that 1 A Well, not every single item have I made the 

2 didn’t require a reply, but generally I think most of the 2 hamination about. You know, archives have indicated to us 

3 personal correspondence was listed at that point. 3 that we - that you can separate personal correspondena 

4 Q Where is thz conespondence list maintained? 4 items out, but we have --just because we don’t have the 

5 A Re~h=cpstlxxnforawhile. Shetlxngoes 5 paso~cl often to deal with it, then I often send, you know, 

6throught.hcmandsmd.sthemonto~fds~t. 6 everything over there. 

7 Q And you indicated that tlx list would be 7 And everything has not been sent over there. I 

8 periodicallygiventothe&sidentforhisreviewtosee 8 just - I want to be clear about that. I have not sent 

9 thosethingstowhichareplywasnotnecessary? 9 evuyth&toRecordsManagen~~~tbecauseIhaven’thadthe 

0 A That’s carrtct 10 time to go back through it all personally and make a 

1 Q IsacopykeptbythePmsident,ordoesIr:give 11 &termination about it. 

2 back the list that you provide him? 12 Q But,Itakeifasageneralrule,though,youdo 

3 A Hegivesitback. 13 not destroy correspondence to the President, whether it’! 

4 Q Is any distinction ma& when the President gets 14 hmc@zhed as personal or offhzial. 

5 -cc betwee b correspoudence and official 15 A That’s cOrrect 

6 contspondence? 16 Q If President Clinton were to ask you to give him 

7 A Tellmewhatyoumeanbythat. 17 any correspondence be had received from Kathken Willey, 

8 Q We&if scuna~~ writes the Resident a thank-you 18 wb&er it would be characterized as personal correspondez~ce 

9 noteasopposedtoagovemmen t official writing the 19 or official co~pondence, I take it, you would have 

o President a letter about offlcial business, are those kinds 20 camplied with that request. 

I of things distinguished and put in different places, or do 21 A Yes, Certain@. 

2 they ail go ti office of Records Management under their 22 Q I mean, the fact that it was personal 

3 record-keeping system? 23 auzs@ndence, for example, would not cause it to not be 

4 In other words, you talked about the’s personal 24 within President Clinton’s control. 

5 colzspon~~andtt.Ialthac’sofflccofRccords~s 25 A Ask that again? 

Page 26 Page 28 

1 although eventually things that are in Personal 1 Q The fact that it was personal cormpondence 

2 Correspondence go to Office of Records M-t. 2 wouldn’t take it out of Fhsidemt Clinton’s control. In 

3 Is personal correspondence lazpt differently from 3 other words, if he wanted a copy of his personal 

4 official correspondence? 4 correspondence from Kathleen Willey, all he would aced to dc 

5 A Well, I don’t understand precisely what you’re 5 is say, ‘I’d like a copy of that correspondence,” and he’d be 

6 asking me. h what way? 6 given it, wouldn’t he? 

7 Q We& using my example, if someone writts the 7 A He could ask that from, you know, various offices 

8 President a thank-you note as opposed to a letter from a 8 asIdidindicating--Imean,asIhadl~ked,andit~k 

9 govanment official on official governmen t statiomy, I take 9 months. Itmaynotallbeinoncplace,anditmaytake-- 

0 itthatexceptfortbeperso&aotesthatyoudetezmineaeed 10 it may not have been all filed properly yet. And them 

1 to be destroyed, both of those am maintained 11 usuallyisn’ttheneedtogothroughanddoallthatquickly 

2 A what’didyousayaboutperson&aotesthatuxdto 12 and f& it all quickly. It just takes some time to think 

3 bedestroyed? 13 abouttheseitems,so4 Q Ithoughtyousaidthereweresomethingsthat 14 Q Okay. 

5 wouldcomeintbeofficcthatyoumadtadctermination- 15 A But if he asks for correspondence, certainly we 

6 A That was my persons correspondence, I think iS 16 would make an effort to comply with his request. 

7 what you asked me, not correspondence to thz President. 17 Q To the best of your recollection, President Clinton 

8 Q M right_ Anything to the President, whether 18 llasDevexaskedyou- or to the best of your nxoIlection. 

9 personal or official, is not destroyed. You don’t make that 19 has President Clinton ever asked you to look for 

o kind of deter&nation that - 20 correspondence related to Kathleen Willey? 

1 A That’s CofTect. 21 A I don’t recall that the President has ever asked me 

2 Q Okay. So both of those kinds of items are going to 22 for - to look for correspondence related to Kathleen Why, 

3 bemaintairrd~bytheOffiiofRecords~~ 23 but he might have. 

4 both personal notes to the President and then official 24 BY MR. WISENBERG: 

5 correspondence. 25 Q If the President ever asked you -- I’m asking this 

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a little narrower than Mr. Bargcr did. If the President ever 

a&cd you to retrieve any corrcspondtmce, wbcther personal 0 

official, you would make your best effort to do so; is that 

Correct? 

A Yes. 

Q You would not tell him, “No, I refuse to do that”; 

is that correct? 

A That’s colTect. 

Q And if you asked somebody in the White House t 

assist you in looking for correspondence or for - let’s just 

start out for any reason, for any reason at all you have for 

looking for it, if Nancy Hcmnzich asks somebody to bclp her, 

they’re going to make their best effort to do it; is that 

Correct? 

A Well, I would hope so, but sometimes I question 

that. 

Q &tainlyiftheyareinyourChainofwmmand, 

un&meathyouintbechainof cOmman&isthatcOnect? 

A I would hope so. 

Q I mean, presumably, if you went up to Erskine 

Bowles and said, “I nad you to stop what you’re doing and go 

look for the Kathleen WilIcy corrcsponckznce,” presumably he 

could tell you that he was too busy to do that; is that 

correct? 

A He could tell me that, yes. 

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Q And presumably you would ncvex go to Erskine Bowlc 

to ask for general correspondence, is that conect, as an 

example. 

A Yeah, well, cerGnly in his present position, I 

wouldn’t ask him to look for it. 

Q But anybody who you would normally ask to perform 

task for you in your normal &y-to-&y business, if you went 

to them and said, “I riced this c~nzspondence,” you would 

expect them to get it done; is that correct? 

A I would expect them to. 

Q And that would include if you directly or 

indirectly asked Office of Records Management; is that 

correct? 

A If I a&cd Records Management to do it, they would 

do it. 

Q Thanks. 

BY MR. BARGER: 

Q Let me finish up on this records topic point and 

move on to another one by going back to the correspondence 

lists. where are the correspondence lists maintained? 

A Well, I think I said this before. 

Q 1 apologize if - 

A That’s okay. I think Rebecca Cameron - I give 

them to my assistant, who’s Rebecca Cameron. I think sbe 

holdsontothem,andatsomcpointwbenshehastimctogo 

I 

-Paeem March 31.1998 

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throughtbcm,shcgoesthroughtbemandthensendsthemit 

directly to management 

Q So tky, too, would be eventually maintained by thz 

Office of Records Management_ 

A Yes. 

Q I think we covered this last Thursday, but I doz*t 

thinkweTHE FOREPERSON: Break? 

MR. BARGER: Break? 

THE FOREPERSON: Since you’re about to c@ - 

MR BARGEFt Yes, ma’am. 

THE FOREPERSON: -1thinknowwouldbeagcod 

timefortkgrandjurytotakeabreak, 15minutes. 

hULWEiENBERG: AU-minUtebreak,andwe’~com: 

get you whxl we’re xady. 

THE WITNESS: okay, fim. 

(Witness excused_ Witness recalled.) 

MRWISENBERGZ Lettherecordrefkztthatthz 

witnessbasrecntaedtbegrandjurymom. Am&Ma&m 

Fo~wehaveaqwrum,dowenot? 

THE FOREPERSON: Yes, we do. 

MRwIsENsERo: TkEarewunauthoriz4Xipersou5 

in the grand jury room, correct? 

THE FOREPERSON: No, there are not. 

Ms. Hernreich, you’re still under oath. 

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THEwlTNJSs: Thankyou. 

BY MR. BARGER 

Q Ms. Hemreich, I have a few follow-up questions 

beforewcmovetoanewtopic,andtherearealsoacoupkof 

questions that the grand jurors have raised that I be& 

we’ll cover as well. 

First of all, to the best of your recollection, did 

you ever tell the P&&dent that you were looking for 

Kathleen WiIley-related conespondence? 

A Idon’txecallifIevertoldhimthatIwas 

looking for it, but I - but I possibly did. I - I can’t 

saywithanycertaintythatIdidordidn’t. 

Q Allright Regardlessofwhetheryoutoldh&to 

bestofyoraknowladge,wastbt~identawarcofthcf~ 

that you were looking for Kathleen Wilky-related 

correspondence or did he come aware of that fact? 

A Idcm’t~havingaamvcrsatioawithhimabout 

it. 

Q I understand you don’t recall a conversation. 

A Mm-hmm. 

Q But given the fact you said earlier you looked fat 

thiscontspondcnceoverasignifi~tperiodoftime,wha 

isyourundcrstandingofwhetkrk~awareofit? I’m ’ 

not asking you whether you had a ccmversati~ I’m asldng 

wbcther,undcrauthc c&ums&mcts,whetbcrthePresidez 

Page 29 - Pag: 32 
----- * a- March 31,1998 

Page 33 Page 3: 

1 became aware you were looking for or had been looking for 1 Q Do you know if anybody else has? 

2 Kathleen Willey-related correspondence. 2 A Well, I assume that the Counsel’s Office has 

3 A Idon’trecallhaving-allIcantellyouis,I 3 because there’s a document request right now - 

4 don’tzeeallkvingaeonversationwithhim. SoIdon’t-I 4 Q Okay. 

5 don’tthinkkwasawareofit,justkcauseIdon’tever- 5 A - and tky would ask Records Management to look 

6 I don’t recall having that ccnversation that I was looking 6 for a.II that. 

7 for it. 7 Q Prior to tk OIC document request - and I may have 

8 Q Didyouseean~gorhearanythingorcometo 8 covered this with you; I apologize if I did -- prior to the 

g anyu&rstanclingthatkmaykvebecauseawareofit,for 9 olc doxxmalt rcqucsf did anyone eaanpt to lo& for Kathkcn 

IO example, from Bruce Lindsey7 In otkr words, you say you 10 WiIIey correspondence to you? 

I 1 don’t recall having a conversation with him - 11 A I don’t know. To Records Management? 

I2 A uh-hrh. 12 Q Correct. You’ve aheady indicated that you 

:3 Q - but you earlier indicated that you gave the 13 didn’t - tkre are things - you have not found - strike 

i4 doctmxatstorvrr.Lindsey. Sofmmwimtyousaworobscrval 14 that. Letmemake we aboutthat. 

;S orheard,didthcRtsident,tothebcstofyourknowiedge, 15 A hf.m-hmm. 

16 beumxawareoftbefacttbatyoubadlookedforKatbken 16 Q Have you found any eomxpondenee from Kathleen 

17 Willey-related correspondence? 17 WiIIey to you? 

18 A From Bm Lindsey or that - you’re asking me 18 A I think that - I don’t know wkre - I don’t 

19 wktkrtkPr&lent-didanythiqinckatetomethatk 19 reeallismyanswer. ButItbinkintkthingsI’veseenin 

!o was aware of it because Bruce had possibly told him? 20 the paper, Mr. Barger, it indicated also that there was a 

!1 Q ~nlY,yeS. 21 note,Ithinlc,tomintbat. AndImaykwrongaboutthat, 

!2 A k that what YOU%?. aSkiIig IIX? 22 but in the publications. And whether they found that -- 

!3 Q Your best redhction is you didn’t have a 23 wktkrIgavethattotkmorwktkrtkygottbatfrom 

!4 conversation with the President. 24 Records Management I don’t know, Counsel’s Office. 

!5 A Yeah. 2s Q All right, let me perhaps - 

Page 34 Page 3t 

1 Q But since you gave the records to Mr. Lindsey, and I A I just don’t remember. 

2 Mr. Lindsey is a close adviser of tk Resident, it certainly 2 Q I’m confused. 

3 is possible, is it not - 3 A Yeah. 

4 A bh-hmm. 4 Q You’ve seen some media accounts that there was 

5 Q - that Mr. Lindsey made the President aware that 5 correspondence from Kathleen WiIley to you. 

6 you had looked for tk eorrespondauz and that Mr. Lindsey 6 A IthhkS0. Ithinkthatthat'S-hkn,Ican't 

7 had been given the correspondence. 7 even runember - I obviously can’t remember what happened 

8 A Well, that’s certainly a possibility. I don’t 8 lastweekortkweekkforeinsomecases. Butitseems 

9 recall that tk President indicated to me that Bruce Lindsey 9 likethat’swkt’sbeeninthepapaorthenews~lles, 

o told him about the conespondenee I had given him. 10 that~wereotherlettetsthattheWhiteHousereleased_ 

1 Q To the best of your recollection, did you throw 11 - at least one, a note that they released. 

,2 away any eorrespondenee from Kathleen Willey to you? In 12 I’d have to go back and look at it. If you’re not 

.3 other words, you already talked about tbe fact you did not 13 aware of it either, then I could have just - 

4 throwaway contspondencefromIcathleenwiIleytIlatwas 14 Q Butthisisanote- as you understand it, this is 

.S addressed to the President. 15 a note from Kathleen Willey to you. 

6 A I don’t recall throwing any of it away, but I’m - 16 A That’s my ECOkCtiOII. 

,7 I have - I’m aware that she’s indicated that she sent M 17 Q Okay. 

.8 thingsthatIkvenotstxnwknI’vesearehedforit,so- 18 A But if it’s not something you remember,then- 

.9 Q Okay. That creates a follow-up question. Given 19 Q Well, let’s assume that fact. Let’s assume that 

!O your ~rhrsmding that she has sent you eorrespondenee or 20 the White House released a piece of eorrespondenee from 

!I things that you have not been able to locate, have you 21 Kathleen Willey to you. 

2 attempted to or caused anybody to look at the Office of 22 A Mm-hmm. 

!3 RecordsM anagenenttoseeiftbaewasanycorrespondence 23 Q Ifthatiscorrect,didtheWhiteHousegetthat- 

!4 from her to you? 24 how did the White House come to have that document? Was tbat 

!5 A I have not done that, no. 25 somethingyougavethem,orwasthatsomethingthatwasin 

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the Office of Records Management? 

A I don’t know. 

Q Was it something that you found recently and gave 

to anybody in tbc White House or anybody? I mean, I must not 

be making myself clear. 

Have you found any correspon &lxx from Kathleen 

Willey to you? 

A I received a letter in December from Kathleen 

Willey. 

Q DecemberA Of 1997, or November of 1997, which I gave to the 

Counsel’s Office 

Q And Hmen did you give that to the Counsel’s Office? 

A Shortly after receiving it. 

Q Who in the Counsel’s Office did you give that to? 

A 1 gave that to Bruce Lindsey. And it could have 

beenNovemberorOctolxrorDecember. Idon’tmcalltk 

exact date, but it was before the holidays. 

Q Aside from that single letter, have you found any 

other correspondence from Kathleen Willey to you? 

A Idon’t remember. Again, I just - I found - I 

don’t know if I found anything, if my assistant found 

anything or if it was to me or if it was to the President. 

Some letters were found. I don’t know if we found them in 

Records Management. I have not reviewed all of thaf either 

Page 38 

1 from newspaper articles or in the Counsel’s Office or 

2 anywhere else to -- to see that, determine that. 

3 I don’t remember whether I found anything from 

4 Kathleen Willey to me, is my 5~swer. And I’m trying to be 

5 helpful here - 

6 Q Okay. 

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A - very honestly, but my answer is, I don’t 

remember. 

Q And when you say you don’t remember, you’re talking 

about the documents that you testified to on ‘Thursday that 

you found that you turned over to Bruce Lindsey? 

A That’s correct. 

Q Is that what you’re talking about? 

A Yes. 

Q And that wouldVinclude a couple of documents that 

Rebecca Camuon found and then tbc ok documents you found, 

that you then, in total, turned over to Bruce Lindsey; is 

that correct? 

A It wasn’t quite like that. It was maybe like one 

at a time. And you’re - you visually indicated that I 

pulled them all together and handed them to Bruce Lindsey. 

AsIfoundtbese,Iwouldbandtheseto-orsendthemtc 

Bruaz Lindsey. 

Q Okay. So you did not give them to Bruce Lindsey 

all at once. 

Multi-Page* h%arch 31,1998 

Page 39 

1 A That’s my recollection. 

2 Q So how many times did you give Bruce Lindsey 

: 3 documents relating to Kathleen Willey? 

4 A I don’t remember. 

5 Q Well, give us a range. More than once? 

6 A More than once. 

7 Q Lessthan20times? 

8 A Less than 20. 

9 Q Lessthantentimes? 

I 10 A I don’t recall. 

1 11 Q okay. Deftitely less than 20 times? 

1 12 A Nothing’s deftite. I don’t - I don’t think it 

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. 21 Q All right. 

22 A And I don’t remember. And23 Q Morethanthreetimes?. 

24 A I believe mom than three 

25 Q More than four7 

13 wasksthan20times-Ithinkitwaslessthan20times. 

I4 Q Morethanoncc. 

I5 A And I believe it was more than once. 

16 Q Morethantwice? 

17 A I believe it was more than twice 

18 Q You can see how this is going. 

19 A I know, but I don’t remember. If1 remembered I 

20 could tell you. 

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A I don’t know. 

Q Okay. 

Page 4k 

A That may be our limit here. 

Q WhenyougaveMr.Lindscytheszreunds-ornot 

when. Wasanytypcofrccordevcrma&ofyougivingthese 

documents to Mr. Lindsey? 

A No. 

Q What was the subject matter, as best you recall, of 

the letter from Kathleen Willey to you in approximately 

November, &xember of 1997, the ox that you turned over to 

Bruce Lindsey? What was the subject matter of that? 

A KathIeenhadaskedtobeinvitedtoaWhiteHouse 

Christmas party. 

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: A No, I don’t recall how many. 

: Q More than once? 

: A Morethanonce. 

; Q Morethantwice? 

. 1 A More than twice. I don’t know. 

L 1 

Q Andthatwasakttertoyouasopposedtothe 

President? 

A Yes, it was. 

Q Do you recall approximately how many other times 

Ka&lecnwiueyllasti~let&stoycnlasopposedtetk 

President? 

Q Iunderstand I 

Page 37 - Page 40 
1369 

Multi-Page'w March 31,1998 

Page 41 Page 4, 

1 A Youwanttosayarangetobeginwith. Youwantto 1 recollection. 

2 saybcnrccnoncandfiveoroncandtcn? IwouJdsaybctw&n 2 Q Is it fair to say -- letmeuseJuly’97asa 

3 oneandten. 3 beocbmark. And the reason I picked that -- or July, August 

4 Q All right. But you also said more than two. 4 of ‘97, because around August - late July, August is when 

5 A I believe - okay, between two and ten. 5 there’s an article by Newsweek and by the Drudge Report 

6 Q Generally, as best you recall, what -- do you 6 bavingtodowithtbe- sort of the Kathleen Willey incident 

7 nx.aIl tlx subject matter of any of those letters she wrote 7 or the allegations about the incident. 

8 toyou? ~i&fromtizmfmznNovanber,Decanbcrof%’, 8 A h&n-hmm. 

9 doyourecallthesubj~tmatterofanyoftbeotherlenas? 9 Q Letmeusethatasabenchmark. Priortothattim 

0 A No. 10 period, prior to the summer of ‘97, how would you 

J Q And just so I understand you, you do not recall J J characterize your relationship with Kathleen Willey? Was it 

2 wktkrornotanyoftbeseotberletterswcretumedoverto 12 a friendly relationship or an unfriendly relationship? 

3 MLLindsey. 13 A I would characterize my relationship with Kathleen 

4 A Anything that I found from Kathleen Wiley to me or 14 W&y as friendly. 

5 to the President I gave to Mr. Lindsey. I5 Q Again, using that time period as an approximate 

6 Q Okay, 3 understand. But whatever that is, you 16 benchmark, again, July, August ‘97, do you recaU when it wa 

7 don’t recall if you found letters from her to you. 17 approximately you began looking for the Kathleen Wii8 A ‘Ihat’S correct. 18 related correspondence? 

9 Q Were the majority of the items you turned over to 19 A 1 believe 1 began looking for the conespondence 

0 Mr. Lindsey letters to you or to the President? 20 approximately in July of ‘97. 

J A MyrecollectionisthattheyweretothePresident. 21 Q There was a - I may not have the phrasing right, 

2 Q Doyourecal]- other than the November ‘97 22 but one of the grand jurors had a question. 

3 letter, do you recall the approximate da&S of any of the 23 A JUROR: Can I ask it? 

4 other atrxespondence f&n Kathleen Willey that you tumed 24 h4R. BARGJZR: Yes, ma’am. 

5 over to Mr. Lindsey? 25 A JUROR: You just mentioned that you started 

Page 42 Page 44 

J A No, I don’t recall the dates. J looking for those documents in July. 

2 Q Do you know any years? In other words, was this 2 THE WITNESS: Uh-huh. 

3 fairly recent correspondence? Is it fairly old 3 A JUROR: Was anything produced in July? Or when 

4 correspondence? 4 were the documents produced and given to you? 

5 A I think it was old. I mean, basically, from ‘93 to 5 THE WRNESS: To me? I don’t know if I found 

6 ‘96. But &nly not in the last, you bow, six months or 6 anythingorifRebeccafoundanythinginthatpaiodoftime 

7 year, I believe. 7 immediately or not. Again, it was - it was over a period of 

8 Q When Kathleen Willey wrote to the President, 8 time, and it was done somewhat informally. 

9 mechanicallywasthat--~tI’mhyingtoaskis,doesthat 9 Since we didn’t have a formal document request, 

0 corresponda~~ COM through you? Would sbt address it to tk IO there wasn’t a pressing need to sort of locate these 

J President in care of your attention and would you then turn 1 J documents in a time frame, and so we casually looked for it. 

2 it over to the President, or is that something that just is 12 So I probably found something in that time, but I 

3 handled routinely that doesn’t go through you? 13 couldn’t say definitively that I did. 

4 I mean, if you uu&rstand my question. Would she 14 A JUROR: Is there anything special that hap-d 

5 trytohavethecomSpondGncetothcPreSidentcometbrougb 15 withinthelastfewvlvetksthatwouldpnrmptamore~t 

6 you, or would it go through normal - and I don’t mean to 16 requesttofindthesed ocuments, say, like the 60 Minute 

7 suggest by not going &rough you it’s not normal channels, 17 intervieworsometbingthatpmmptedeveryonetonzallygo 

8 but other channels. 18 and search and find these documents? 

9 A My recollection is that she -- that it would go 19 THE WITNESS: I don’t believe that I have located 

3 throughme. 20 any letters since the 60 Minutes interview, and no one has 

I Q ti right. Is that because of her request, or is 21 askedme-otberthanwebaveageneraldocumentreqti 

2 that just because that was tbe way it routinely was handled, 22 right now that we nceived. I was out of town for a few 

3 oristhatbecausesinceyouknewMs.Willey,itwasdinxted 23 days,butwbenIgotback,IthinkIbadittbebeginningof 

4 to you? In 0tlx.r word& what - 24 last week from the Office of Independent Counsel looking for 

5 A I believe she addressed it to me. That’s my 25 documents related to Kathleen Willey. 

._ - . 

Page 41 - Page 44 
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But no one had asked me to produce or to look 

further for things since that interview. Is that what you’le 

asking me? 

A JUROR: Well, kind of, because what I would like 

tolcnowis,wasthenzanyspecialreasonthattheyweretbcsc docuxxtam materialized immaihly afta tbc 60 h4i.nu&~ 

broadcast? 

THE WITNESS: I had nothing to do with that, and 

that-andsoIcan’tspez&tothat. Ihadgivenevcqhiq 

IhadfoundalreadytoMr.Lin~,andsoIon’tspeakto 

whytheywemproducedatthattimc. Ihadaopartinthat_ 

A JUROR: Can you recall as close as possible wlx?r 

youturnodovcrthedocumcnts-orthefrnaldocrrmcntthat 

you found to - because I know that it was in pieces. 

THE-S: Yes. IthinkthelastdocumentI 

handedoverwasthe-atleastlettcrorcorrespondcncewas 

the letter that I received prior to Christmas asking to be 

invited to a White House Christmas party. So October, 

November, December, in that range. I believe that was the 

last one that I located, or that Rebecca found. 

BY MR. WISENBERG: 

Q But that would have been virtuaRy amtempomneous, 

I take it, your getting it and turning it over? 

A That’s ~~rre!ct. 

Q How about before - before then, you’re doing a 

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historical search; is that correct? 

A Yes. 

Q Whatdoyourememberasthelast--~wasthe 

last one you would have turned over, the last piece? 

A I don’t - I really don’t remember. It was prior 

to that, so -- and I think I probably got that letter in 

November sometime. So it seems like Reti found some 

things later on again as she was going through filin& and it 

-- maybe it was in October sometime. But I - I don’t 

remember. 

I just remember it was over a period of time. We 

didn’t find them all at once. And we were doing it pretty 

much on our own, you know. Tbcm wasn’t a pressing need ta 

fmdthemaIlatonetime. 

THE FOREPERSON Can I ask you a question? 

THE WITNESS: %.re. 

THE FOREPERSON: Pm just curious, and I hope I’m 

not out of line here. Do you have a high regard for the 

President’s job and the job that he’s doing? 

THE WlTNESS: Yes, I do. 

THE FOREPERSON: That being the case, would you not 

fmd a sense of urgency to try to find these articles that 

would sort of dismiss some of the allegations that are 

swimming around? 

Even at that time, even July, August, September, 

Pagem March 31,1998 

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would there not have been a sense of urgency and more 

attention to detail in finding these things, that given the 

caSe,kllOwingtlWsoItlHW you admire and respect is unde 

fire? 

THE WITNESS: Well, I don’t - I don’t read the 

Drudge Report, number one, and my recollection - and 

somebodycorrectmeonthis-I’maot-theremayhavebeer 

an article in Ncwswczk that I do not remember, that them was 

anarticleinNcwswcek,~dsoIguessIdidn’tsfflsethat 

there was an urgency about the allegations at that time 01 

that - I didn’t have that sense about it_ 

And I’m not sure that I knew ever until, you know, 

rccCntlywh?lthcrlilltgationSunsCatal.l,OrwllatwaSevCn- 

- and I possibly did, you know, may have heard rumors of the 

DnrdgeRepcr&butcert&lymaybcnotuntiItbclastfew 

weeks~youknow,moreoftbe~hascomeabout~l 

I know what her allegations were. 

THE KMEPERSON: &o, is part of your job to sort 

of put out firs before they beumxz huge flattxs? And if you 

see there is a potential problem, to - to avoid having the 

PmsidentspardhistimeontbesesmalIthings. Youwanthim 

todohisjobof running the country. 

When you see that there is a potential problem and 

itmaytakchimawayffomtbatjob,wouldyoubringsomrhing 

tohisattenriootosay,‘*IhisisI’mgoingtodoaboutthis 

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issue”? Say, for instance, “I think I better look for these 

le~btcausethiscouldbeaprobleminthefutun,andI 

know you have these other things on your plate right now, so 

I’m taking it upon myself to do this.” 

Isthat-canyoutellme,isthatsomethmgthat 

ispartofyourjobde.scriptiontosortoftalcecamofthe 

smalltaskssothtPresidentcanhandlethtlargeones? 

THE wrm~~s: Possibly, but - but I’m not sure I 

would have a convQsation with the President about that. I 

would more likely, if I felt like it was a legal issue, have 

a umversatiotl with the Counsel’s Ofhce rather than with the 

President himself. 

A JUROR: Excuse me. I have a question on the 

Newsweek article. You stated that you don’t recall the 

Ncwswo&micktbtcancoutamundAugusthutKathkm 

wiIl9. 

I would suspect an article that involved someo~lc 

who was so closely involved with the President and you 

office would cause some talk in the offi. You don’t recalI 

reading that or being conscious of the seriousness of the 

content of that article? 

THE wlTNESS: Well, I think, you know, my - tl 

series of evarts have gotten muddled, and I thought - and 

11 this is my recollection of it, whether this is act&y wha 

happened or not -butthat-andthisismostlyin I 

Page 45 - Page 48 

c 

.-_ __ . - . d__^. _^P ^-a- 
1371 

Multi-Page” March 3 I,1998 

Page 49 Page 51 

1 retrospect. I thought the Drudge &port was on the article 1 Q Do you recall that there acre several’ follow-up 

2 that I&off was going to write for Newsweek but my 2 press stories about the Newsweek article? 

3 rezollection is that it wasn’t in Ncwsweck. Now, it may nave 3 A Again, time-wise, you know, I don’t know. I don’t, 

4been. 4 again, know the dates or - I really don’t. And if you 

5 But, you know, I - I - frankly, I just don’t 5 showedthemtomeandyousaid”Herearethearticles,”I’d 

6 remember, you know, if - obviously I do not remember if 6 say, “Okay, fine,” you know. 

7 tberewaaaspecificarticleinNewsw&aboutthat. lbere 7 But I do every day. I mean, if I read these every 

8 weretkal@&ns,apparcntly,intkDrudgeRtpors~cb 8 day for tk last five years, and thcrc am probably 200 pages 

9 I don’t read. And some of those things swirl around you, but 9 in those, and I might k reaclin8 about, you know, Bosnia or 

10 it’s not - you asked whether it’s my responsibility. 10 Iraq, I might k reading about tornadoes or hurricanes, and 

I1 If something comes to my attention. But it’s tht 11 intbatisastoryonKatb.leenWilley. But2OOpa8ea.365 

12 Counsel’s, you know, responsibility or the President’s 12 days a year for five years, I can’t tell you that I read tha 

13 pemonallawyerstotakecamofthose~andnotminc 13 particular article in August 

14 neccs&ly. Andifit’ssen&ingtkatisblatantandIsae 14 Andthat’sjustoneofthethingsIdoevmyday. 

IS it,thencertainlyIwould,youknow,~todosomething, 15 That’s, you know, out of the 2$00 -- well, it sometimes 

16 youknow,forin&mce,bkethocom%pon denceorwha&ver. 16 feels like 2,000, I’m sure that’s a bit of an exaggeration. 

.7 But if it wasn’t, you know, blatant, t&n it’s something the 17 But the several buudred, you know, pieces of cotrespondence 

18 Counsel’s office should handle. It’s oot my xsponsibility. 18 an4youknow,phonecallsorstaffnqueststhatIgetevery 

.9 BY MR. WISENBERG: 19 &y,andIjust-~antoomanvthingsgoingon,andI 

!O Q Pardonme. l’bequcstionwaa,didyouhcaranytalk 20 can’t remembcrcveqthing. Yes? 

!1 aboutit- 21 A JUROR: a of 

!2 A Idon’t- 22 allegations -- 

!3 Q -- around that time? 23 THE WlTNJzss: Mm-hmtn. 

!4 A DidIhearanytalk? Well- 24 A JUROR: - of the incident, what factors might 

!5 Q “It” being the allegation. 25 have prompted you to take it on yourself to search for 

Page 50 Page 52 

1 A Yeah. Well, again, the specific allegations, I 1 eonespondenee and turn it over to Bruce Lindsey? 

2 don’t know that I was very aware of that until just recently, 2 TFUZWITNESS: Ithinkwhatstartedit-andthis 

3 what the specific allegations were in the papers recently. 3 maykwhereI’mgettingalittlebitmixedupoowhetherMr 

4 Q Let’s talk about the general allegations, the 4 Bennenaskedmetolookforitoroot-wasthatkbccame 

5 incident that occumxi with Katblcen W&y and the President 5 aware of the allegations and brought them to my attention. 

6 in the oval office. 6 And I had, you know, I think testified to on 

7 A I would have to say probably, would k my answer to 7 ‘Ihursdaythatkhadcalledmeandaskedme-I’mnotsure 

8 that without, you know - but I couldn’t tell you 8 iftbeywerespecificalle8ations-ifIknewofthiswoman, 

9 speeifieally who talked or, you lmow, what kind of 9 everheardofha,everknewifshebadseeathcResident. 

0 conversations were held or maybe you heard, “Well, there’s a 10 So -- and maybe I didn’t know specific ahegarious, 

1 Drudge Report.” 11 butgeaaallythatsbewasgoingtomakesomeallegationsand 

2 But may I say also that in August - and I don’t 12 thought, well, at some point somebody’s probably going to asl 

3 know when this article came out - but the Resident was on 13 me for this, so I’ll just start looking for it now. 

4 vacation for about three weeks, and sort of - and in that 14 And - and, as I said, started looking for it, and 

5 period of time thin@ are very quiet in our offke. And so 15 diditoveraperiodoftimebecausethcredidn’tseerntobe 

6 being that swirls kind of follows him, and it wasn’t in my 16 the urgency to look for it. 

7 particular, you know, area 17 Does that answer your question? 

8 So that was a period of time, those several weeks 18 AJUROR: Yes. 

9 inAugust,youknow,tben,thatmostoftbepeoplewereout 19 BY MR. WISENBERG: 

:o of the White House at that time. 20 Q Do you recall Robert Bennett’s statement around 

,l Q Do you get - you get a press clipping packet every 21 this time to the effect that Linda Tripp is not to be 

i2 day at the White House. 22 believed? Linda Tripp kin8 tk person who said sbc saw 

3 A That’s right, I do. 23 Kathleen Willey leave the President’s office and indicate 

14 Q Do you usually read it? 24 that something had occurred tkre. Do you recall Mr. 

15 A ItD’to,yeS. 25 Bennett’s statement to that effect? 

__- -- 

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A Oh, I certainly don’t recall it at the time, no. I 

mean, I couldn’t - certainly I’ve read it since then, but 

for it to have made an impression upon me -- I don’t recall 

that it made any kind of impassion upon me nor do I xcmanba 

that hc said it at the time. 

MR. BARGER: I think there was another grand juro 

that had a question. 

A JUROR: No, that ixfmmed myquestionattbcsame 

time. 

BY MR. BARGER: 

Q Let me follow up with the Newswezz k article related 

to the other grand juror’s question. 

I take it that you did not start looking for 

Kathleen W&y-related correspondence until after the 

conversation with Mr. Bennett. 

A That’s my reeolleetion. 

Q And as you just testified to, at least as best you 

recall it, the conversation with Mr. Bennett, in par& 

umcclned the fact that Kathleen wiiey was going to make 

these allegations. 

A He,Ithink,hadheard-Idon’tknowthatshewa! 

going to make the allegations, but he had heard some sort of 

rumors, I think. And maybe - obviously that follows, but - 

Q That it was possible that these allegations were 

going to come out, 

Page 54 

A That maybe he heard a rumor -- I think you’d have 

to ask Mr. Bennett, you know. I know that’s not possible, 

but -- 

Q 1 WOt&tI’t dismiss that. 

A Pardon me? 

Q Nothing. 

A But maybe he bad heard about the Drudge Report or a 

potential, you know, Isikoff story or - 

Q Is that your impression, that perhaps he was 

callingyoubecausehehadbeardanunororheardsomemedi; 

reference or the media was checking around about this 

possible story, and that maybe there was going to be a story? 

Does that sound - is that consistent with what yet 

recall Mr. Bennett calling you about? In other words, if the 

story had not come out, perhaps there was going to be a 

story? 

A I’msureMr.Bennettcalledmebecausethenwas 

some sort of either - there were nrmors going around either 

about a potential story or potential allegations of some 

sort. 

Q Using that July time period, that period Mr. 

Bennert called you to the present, has anything - has there 

beenany-andI’mnottryingtobefliphxe-hasthen 

been any significant stress - I’m sure the job you have is 

stressful. Has there been any significant stress in your 

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Page 55 1 

life, or has something happened to you that would affect your 

memory between July and today? 

A No. I can’t think of anything that -- other than 

the normal aging process. 

Q Okay. What was significant about the President 

being cm vacation for thresz weeks in that same time period 

thatcausaiyouto mnanbu that, but unablt to runaubusJmc 

of the other details we’ve talked to you about? 

A Well, that’s a huge blank period of time, I mean, 

wberc sort of nothing happmed. I mean, that’s obviously 

something you’re going to remember. It’s so wonde3ful to be 

able to have three weeks without the sort of My, you know, 

four million things that hit you 

AndIhad-I remembered it because I stayed in 

town, I think, for most of that period No, actually, I 

didn’t. I left for some of that. I forgot This year I 

leftfordrefvsttime,andIwasgonefortwoweeks. I 

8 just now remembered that. 

9 Q You didn’t want to spend July in W&hgton, D.C.? 

0 A It wasn’t July, it was August, actually, and I went 

I to-wcntouavacaticmwithmydaugbterfortwcivwelcs. 

2 Q Let me go just briefly back to providing the 

3 documents to h4r. Lindsey. 

4 A Mr&mm. 

5 Q I take it that, as best you recall, you had this 

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Gctobc~, Novunbu. Daxnbm. whateva that approximate date 

is,ofthislettcrfnrmKathlecnWillcyaskingtobeinvitcd 

to the White House Christmas party, airmet? 

A ti-hmm. 

Q You turned that over to Mr. Lindsey. 

A I-hat’s cormet. 

Q ~oftheothercorrespondencefromKathken 

WiIley, which, at least as best you meaIl_ was older - 

gcncrallY 0h.h wrleqKm&nce, you had previously turned 

over to Mr. Lindsey. 

A That’s my recollection, but, you know, there’s a 

possibihty it could have. But I think that was the last 

piece I got - 

Q aright 

A -andthtlastpieceIturnedover. 

Q Usingthatlastpiazasabenchmark,approximately 

howmuchbeforethathadyouturnedovertheearlier 

correspondence? 

A Oh,Ithinkyouallatleasttriedtoaskthat 

earlier, and I don’t remember that specific time. But I 

would just guess it was probably sonzwberc in octotier. Arthat’s with no maI specific rewlleetion. 

I mean, I could go back and ask Rebecca, and 

Rebecca could say, “Oh, Nancy, I gave that to you in midI 

Duxmbu.” And I ban not askai ha. you know, to rccaIl any I 

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Multi-Pagem 

Page 5: 1 

1 of that and what her memory about it is, so -- 1 

2 Q Okay. In the years that you have worked for the 2 

3 Presiclent, both when k was goveroor and in tbe last number 3 

4 of years while k’s beeo President, have you become familiar 4 

s with his handwriting? 5 

6 A Yes, I am familiar with his handwriting. 6 

7 Q Do you think you’d be able to recognize his 7 

8 handwriting if you saw samples, for example? 8 

9 A Itbinkso. Thaem-,yoUknoW,caseSWbcre 9 

0 it’s not - you know, a long document that I might not k 0 

1 able to. 1 

2 Q Okay. Lztmegobacktothefallof1992. We 2 

3 talked about this on Thursday - 3 

4 A h4mhInIIL 4 

5 Q - and I was asking you some questions about -- 5 

6 AJUROR: Mr.Barger- 6 

7 MR. BARGER: &my. A question? 7 

8 A JUROR: Did we ask her a question about the 8 

9 c~m~pondence list? 9 

0 MR. BARGER: Oh, you’re right. I did not. .O 

1 BY MR. BARGER: ,I 

2 Q when you were testifying ea&T befOIt2 the ,2 

3 break- 3 

4 A h’f.m-hmU.L 4 

5 Q -1believetLrewassomctestimonytotfieeffect 5 

A Well, maybe it was, you know, this, and maybe I 

just didn’t pay any attention to it. But it seems like when 

she has -- when she gets around to it, that she brings these 

tomtandsomctimcswillsbowthcmtomeandsay,’ThisisI’m sending all this over to Records Management. I just wan: 

you to look at it and know what I’m sending.” 

Q What I was getting at was, what has happened that 

has caused you to learn something new? In 0th words_ have 

youtalkedtoheraboutthis? Hassomeoneelsetalkedtothe 

two of you about it? I mean, have you had conversations 

about this record-keeping function, about looking for 

documents? 

Whatisitthathashappenedthatcausedyoutonow 

learo something uew that you previously either didn’t kuow’o 

hadn’t nally ken aware of? 

A I think she recently has finally gotten around to 

start getting caught up on her filing, is what I honestly 

think. Sk’s had a volunteer and intern, a former intern 

come in and help her, and so I think she’s finally getting 

caught up in the last six months. And so that’s probably why 

it was brought to my attention. 

Q In other words, it was not brought to your 

attention as a remlt of the grand jury appearance or in 

connection with your grand jury appearance? 

A That’s correct. 

Page 58 

that Rebecca Cameron, I think would review the 

correspondeuce list and then perhaps at sorm point the list 

was going to k sent off to the OffLx of Records Managemenl 

A h,fm-hum. 

Q CiemraIIy, what were her responsibilities with 

regard to the correspoucleooe lists? Why would she review it, 

for example, what would she do with it, that kind of thing. 

A Well, I really don’t know what she would do with it 

intkimerimti.me. Ikuowthat-itseemstome,having 

watched her work, it was sort of her responsibility to take 

it and - in fact, until recently I didn’t know that she held 

onto it. 

But it seems like what she does is when - for 

instance, if the Rsident’s out of town, and she’s got somt 

time where she can actually do some other work, and tlx 

plumes die down a little bit, then she can go back and look 

at all of her filing and catch up on things. 

So then at that point she goes back to those things 

and looks at them and says, “Well, this all needs to go tc 

Records Management,” and goes back through all of kr stuff 

and tries to get caught up on just paper. 

Q Okay. I believe in the interim you mentioned that 

until reaxrtly you didn’t know that she kept it for a while? 

A h4mhmm. 

Q What caused you to learn that fact? 

March 31, 1998 

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Page 60 

A JUROR: what iS she - what are you looking for 

before you decide to send it to - particularly on the 

CorreSpOndenCe. 

THE WlTNESS: We& one of the things that we loo1 

for is a letter that -- that the writer, in my opinion - and 

now I’ll need to qualify this by giving you some examples, 

because I think it’s important to phrase this properly so 

it’s not misunderstood. 

Periodically we’ll have somebody write a letter to 

thePresicknt,anditwillk-theywillwriteiuthereand 

say, “My mother did this, and I just want to clobber her. 

And I’m so mad at my brotber because k, you know, is a jerk 

and he doesn’t treat his children right.” 

And you read that and you’re going, ‘Wow, do we 

want history to read this letter and, you know, read all 

about this woman’s personal family life and that sort of 

thing?” 

So sometimes you - you read them for the 

sensitivity from the writer’s point of view, and I thiok, “Do 

I - would this person want this to be history?” if I think 

it’s particuhuly sensitive, and they don’t want some 

reporter at some Point or historian to go through and read 

thisandtkuhaveitkinthepaper,andsothatthis,you 

know, family tkn is angry at the Resident. 

I can remember those specific cases, you know, 

: i 

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Page” March 3 1,1998 1 

Page 61 Page 63 

where someone has written like tha4 on relationships, family 

relationships primarily, is what I’m looking at, something 

that might offend somebody in the family, or they might be - 

it might hurt them in some way, if it was, you know, 

disclosed. 

That’s primarily what we’re looking for, or what 

Re~Ithink,islookingforaDdwhatshebringstome. 

BY MR. WEFTBERG: 

Q What would she do about it if she got something 

like that? You wouldn’t ndact tbc letter. You would just 

make sure the letter didn’t go over to ORM? 

A Well, I don’t recall having pulled any. She’s 

brought some to my attention and just said, “Look at this 

and” - but earlier there certainly have bum -- and not very 

manyofthem-butafewletteislikethat,whereahigh 

school friend of the President would write or a grade school 

friend, where the President might know the persou’s family 

personflY* 

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Q You mcall seeing Lieutenant Governor Beyer in the 

video, eorreet? 

A Yes, I do. 

Q Having seen that, do you recall - and I’m not 

speaking about the video - but do you recall from your 

recollectiou that Lieutenant Governor Beyer was on the tarmac 

thffeinRichmondto~tthethengovernor~hecamein 

for that &bate? I mean, do you recall Lieutenant Governor 

Beyer being there? 

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A No, I don’t recall Lieutenant Govcmor &ya being 

tlEre. 

Q Do you meall yourself being there? 

A I recall being in Richmond that day, or being -- 

yeah, I couldn’t have told you it was absolutely Richmond. 

Q Okay. 

A But, in reeolleetion, I guess we didn’t land in 

Williamsburg, but I couldn’t have told you definitely it was 

Richmond prior to that. 

Youknow,ifsomebody~upnextdoortohimand 

she’s written and says, you know, ‘My brother” - and I just 

lunaflbcr this one particular, you kocw, woman who would writ 

and talk about her brother and how he didn’t treat his 

children right and now she’s mad at her mother, and you’re 

going, “Now, we don’t” -- 

You know, she does not want that letter to be part 

Q Do you meall - you mentioned Williamsburg. Da 

you recall going to Williamsburg? 

A I recall being in Williamsburg. 

Q Do you recall, is that where then Governor Clintom 

stayed that evening, in Williamsburg? 

A Yes. My recollection is we did debate preparation 

in Williamsburg prior to the debate in Richmond 

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Page 62 

of history. And so you pull that and file it. And in that 

case I might smd it over to Personal Correspondence to file. 

I might fde it in our own files, whatever is most 

convenient, frankly. 

BY MR. BARGER: 

Q When you said you might file it in your own files, 

I don’t -- can you explain what you mean by that? Are you 

saying that there is a -- you have a filing system in 

addition to Personal Correspondence and Office of Records 

Management? 

A Well, Rebecca has - goes through her files 

periodically, but I don’t know if Rcbccca keeps other items - 

- other eorrespondenee in any of her files or not. I don’t 

go through her fties. 

I give her s&s of things to file, and I can’t 

always tell you how she does that, and I haven’t really 

reviewed all that with her recently in anticipation of this 

Q Going back to the fall of 1992, you recall last 

Thursday I asked you some questions about President, then 

Govemor Clinton’s trip to Richmond/Williamsburg for tk 

presidential debate. Do you remember that topic? 

A h’fm-hrnm. 

Q And I showed you a couple of videotape clips to see 

if it helped your recollection. Do you recall that? 

A hhh.tnm. 

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A Yes, I stayed in Williamsburg. 

Q Doyourecallhowmauynightsthatwas? Wasthat 

one night in Williamsburg or two, if you recall? 

A ~thbkitWaSIUOItZthiXIonCtight. IbdiCVeit 

was two, but, you know, if someone camcaudsaiditwasouc 

then I’d say, okay, it was one. But my ncollection it was 

more than one. 

Q CeneraRy the expenses that were incurred for then 

Governor Clinton for that type of trip, which would include 

your expenses as well -- 

A h%m-hnnn. 

Q -thosewerepaidbywho? WasthatbytheA Iassumethosewerepaidbythecampaign. 

Q Did you have any function, any role in maintaining 

any records of those expenses? Let me ask it this way. 

A hfm-hmm. 

Q Do you know whether records of the expenses 

incurred for that campaign trip, like the one in 

Williamsburg, were kept? 

A No, I don’t know if records were kept. 

Q DoyoueverrecaUPresidentClinton,orthen 

Govemorclimlmusingtheexpmssiao-inerdertogetsomc 

free time or to make time available for himself, did you ever 

Page 61- Page 64 

Q And is that where you stayed that evening, in 

Williamsburg? 

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Page 65 Page 6: 

1 hear him use the expression, “clear the decks”? 1 Q W’here does that understanding come from? How did 

2 A No. 2 you gather that - 

3 Q Did you see the 60 h&Wes inkrview of h4s. Wiky? 3 A My understanding came primarily from her, and 1 

4 A No. Isawtheveryendofit,butIdidn’tsee- 4 believe the President felt - it was my understanding from 

5 Ididn’tseemostofit. 5 the President that k felt like they had helped him a lot. 

6 Q Do you recall whether then Governor Clinton talked 6 Q And, I take it, that understanding from the 

7 to Kathleen Wiky that day by telephone? 7 President came from conversations -- one or more 

8 A No,Idon’trecallifhetalkedtoherby 8 cmverS.ation~ you had with the President? 

9 telephone. 9 A YeS. 

0 Q After tht presidential debate, did you attend a 10 Q Do you reed -- after tk President was elected, 

i fundmiser-striketbat. Doyouncallwkthertkrewasa 1 I do you recall wktkr you made any phone calls for tl~ 

2 f&raiser in Richmond after the presidential debate, I 12 President-elect Clinton to thank campaign supporters? 

3 believe, at the Marriott Hotel? 13 A ThatIpersonallycalledpeopletothankthemfor 

4 A ithoughtyouhadaskedmethattheotherday. 14 him? Is that what you’re asking me? 

5 Maybe you asked me about a rally. No, I don’t recall if I5 Q No, I’m not limiting it to that Whether you ma& 

6 there was a fundraiser afterwards, after the debate. 16 phone calls on his khalf, wktkr you placed phone calls for 

7 Q Ididaskaboutarally. AsIunderstandifthe 17 him,wbttherDeitbaofthose~butyouwereawarethat 

8 rally occurred the next day on the grounds of the govemor’s 18 he ma& phone calls? 

9 mansion. 19 A Well, that would have been in my responsibilities 

i0 A hh’hnm. 20 at the time, and I don’t recall specific phone calls, but I 

11 Q AndIthinkyourt&imonywasyoudon’trezallt.k 21 will just say that it seems to me that k certainly would 

12 rally. 22 have made phone calls after the election, and if he did, then 

:3 A Yes, I don’t recall. But you’re indicating to me 23 I would have ken there with him, most likely placing those 

14 therewasafundraiserafierthe- 24 dS for him. 

5 Q &fore the tiy. 25 Q After then President-elect Clinton was elected in 

Page 66 Page 61 

1 A &?fOlCt.kdJf? 1 November of ‘92, do you recall wbetkr there was a time in 

2 Q Yes. 2 and around that period that, I believe, Pamela Harriman 

3 A The day after the debate? Is that what you’re 3 organized a party for the President-elect in Washington, 

4 saying? 4 D.C., in the Georgeto~ area? 

5 Q Ibelieve so. 5 A Afkrhewaselected? 

6 A Obviously I don’t recall it. I mean, that’s my 6 Q Correct. After his election, do you recall whether 

7 answer. But I - I don’t recall any of it. 7 Pamela Harriman threw a party for tk President? 

8 Q Assuming that that chronology was accurate - 8 A No, I don’t recall that Pamela Harriman threw a 

9 A hh!I-hmm. 9 party for him after the election. 

0 Q - you don’t recall whether there was a fundraiser 10 Q Now, I noticed - and you’re certainly free to do 

I at the Marriott in Richmond aFter the debate. 11 so2 A Well; once the debate is over - but I -- you know, 12 A hf.m-hmm. 

3 &t’s - you CBII imagine tit my manory’s like now. You cfm 13 Q - provided it doesn’t interfere with the 

4 imagine what it’s like, you know, six or seven years ago. 14 questions - 

5 I - I don’t remember if1 stayed over. I may have 15 A h’hn-hmm. 

6 literally left early the next morning, because once the 16 Q But I notice you had been taking notes. Can you 

7 debate was over, I probably headed out of there on a 17 tell the members of the grand jury why it is you’re taking 

8 commercial airplane. 18 notes? 

9 Q what was your understanding, or what iS your 19 A For a couple reasons. One, I can nzmember your 

o understanding of what role, if any, Kathleen Willey and her 20 question better and - I think that’s the primary reason. 

I husband had in the predential campaign in 1992? 21 And sometimes I take it afterwards. It’s mostly -- it’s for 

2 A well, I- it was my understanding that they played 22 my benefit. 

3 a, you know, huge role, raising money and, you know, holding 23 BY MR. WISENBERG: 

4 events and were actively involved in the campaign. That was 24 Q Let me just interrupt for a second - 

5 my understanding. 25 A hre, !hl. 

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Q -- and let you know that I direct you not to do 

anything to destroy the documents or integrity of the notes 

because it’s possible we might be subpoenaing them. 

A That’s fiw. 

Q And, 1 take it, those notes are just what you’ve 

taken while you’re in the grand jury -- while you’re in the 

grand jury room? 

A Yes, they’re notes I’ve taken just fiom the grand 

jury. 

Q Okay. So as to avoid redaction problems, we would 

alsodirectyounottowritedown-nottogetina 

conversation with your attorney and write down whet mj&t be 

privileged in your conversation with him on those notes, so 

there might be - to avoid any redaction problems, of you 

having to go through later and redact certain things. 

A Okay. From this point on, you know, but - I mean, 

I don’t know that I’ve done it prior to that, but you’ve just 

now given me those instructions, so - 

Q Yes. It’s our position that anything written down 

in the grand jury room is not privileged. So if there’s 

anything that you’ve written to date that is between you and 

your attorney, if we subpoenaed them, you would have the 

right to redact those. 

A Okay. 

Q So that is part of our definition of doing anything 

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to destroy the documents or the integrity. 

A Okay. 

BY MR. BARGER: 

Q After the President was electal -- so I’m moving to 

after the inauguration, so I’m moving into tbe early part of 

1993. 

A M.xn-hmm. 

Q And you came up to Washington, D.C., to work for 

the President, cornzct? 

A That% correct. 

Q Do you recall -- initially wben you started working 

for the President tbe early part of 1993, do you recall, did 

you sit in the same place you sit down, or did they have to 

move you around? 

A They moved I& around. 

Q Do you recall where it was you initially had your 

office? 

A On the back side of the dining room. It was not il 

the dining room, but on the other side of the dining room, 

and presently Rahm Emanuel is in that off&. 

Q Okay. 

A Actually - let me just back up. The very fti 

place I had my office was in the dining room. 

Q Right. Andthenafter-- 

A Then it went into the office next to the dining 

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room. 

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Q Was that a promotion? I don’t mean -- I know your 

job stayed the same. Was it a better office in the dini; 

room? 

A There were no promotions involved at all in all 

those moves. 

Q Butafterthedin.ingroom,youwentintoanoffice 

ontbebacksi&ofthedinirrPareathatyoubelieveRahm 

Emanuel now has. 

YeS. 

How long, approximately, were you in that office? 

I think four months, four, five months. 

And thzn you moved to wl~~ you are now? 

That’s correct. 

THEF0REPERsoN: Excuseme. CanIaskyoyistba! 

the same offix that m Stephanopoulos had? 

THE !vxTNEss: Yes, it is, uh-huh. 

THE PDREPERSON: Okay. 

BY MR BARGER: 

Q Dire&g your attention to the early part of 1993, 

January, F+bruary. March AprJ uay, scmwbaeillthat~ 

I guess. 

A Early ‘93? 

Q&m 

A Okay. 

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Q Right. DoyourecaUwbetberyoumether-no,my 

questionis,doyouncallintbatfvstsixlllcmthsof 1993 

w&her you met Kathken Willey at the White House? 

A Idon’trecaIlwhethcrImetherattheWhiteHousc 

during that time, but I believe I saw her in that period of 

timc,or,youknow,mctkrinthattime. ButIjustdon’t 

recallit. Ican’tteIlyouwhenIdiditorunderwhat 

circumstances. We can save ail the questions that COM 

afterwards then. 

Q we&ktme-- 

A Okay. 

Q Otherwise, I won’t have as much to do. 

A Okay, weIl - 

Q Do you recall s0mctimei.n 1993 -we&strike 

that. DoyourecaIl,didthereccnneatimewfien~ 

President of the United States gave you some i.nstnhons 

about finding a position for some volunteex work for Katblem 

Willey to do at the White House? 

Page 69 - Page 72 

Page GIL 

Q Co~oratleastthefirsthaIfof’93. Do 

you xezall either calling or ultimately meeting Kathleen 

Willey for the fust time? Strike that. Well, meeting 

Kathleen Willey at the White House? 

A Idon’trecaIlthefusttimeIsawherora 

specific, you know, fm time meeting her. Is that what 

you’re asking me? 

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1 A No, I don’t recall that, no, but -- there are 1 Q In or&r to try to narrow the universe, what is 

2 documents that indicate that, but I don’t recall it. 2 your opinion of where it was you leamed this information? 

3 Q What is your understanding of how it iS or how it 3 A I don’t know whether it was a document or whether 

4 wasthatKathleenWilley--strikethat. lheredideomea 4 it was a publication or a newspaper, I don’t - 1 don’t 

5 time, did there not, that Kathleen Willey began to do 5 remember. And I don’t want to speculate on something that 

6 volunteer work at the White House? 6 absolutely don’t remember. 

7 A I believe - yes, she did do volunteer work at the 7 Q All right. Was it something someone gave you, o 

8 WI&House. 8 was it something you stumbled across by accident? Was it 

9 Q What is your Understanding Of Where it was She 9 something you looked for yourself? 

o worked, or where did she start doing lxr volunteer work? 10 A I don’t remember. 

,I A I don’t recd. Without thest other documents, I 11 Q Well, did anybody give you documents to review or 

2 wouldhavethoughtshestartedintheSo&lOfF~and- 12 newspaper articles to review about Kathleen Willey? 

3 but it is now my belief that she probably started m 13 A No, no one has given roe documents to rev&v about 

4 e1se and then moved to the Social O&e. 14 Kathleen W&y. 

5 MyrecollectionwouldbavelxentbatIbadnotbing 15 Q And I don’t want to play a semantic game here. 

.6 to&withherbeingintheSocialOffice,thatshestarted 16 when1say”givenyo~“1inc1udethattoman,hassome0ne 

7there. 17 shown you documents, has someone discussed doements wil 

8 Q What is your understanding of wlxxe she started 18 you? Let’s not - you kuow, I don’t want to play semantic 

9 before moving to the Social Office? 19 games or - 

!O A Idon’t remember that. See, that’s what I just 20 A Areyoua!&ing-Imeaqinprcparationforthe 

II said. It would have been my - my recollection - and1 21 grandjury,areyouaskiqwhetber someonellasgivrmrnt! 

12 don’tknowwlmeskstartalt+omdccumaitsoranything&c. 22 domments? 

13 I just don’t know where she started. But my recoIlection 23 Q No, I’m just trying to figure out what it is that 

14 would have been that she started in the Social Of’flce. 24 makes you think something different than what you thought ii 

!5 Is that making sense to you? 25 the past. You said that you would have thought she started 

Page 74 Page 7t 

1 Q Yes. 1 in the Social Offtce, but you’ve seeo something meetly that 

2 A I mean, you really get confused after a while 2 caused you to think she asked you for a position. 

3 bccauscyou~thcscarticlcsandyousotdocumcntsandyou 3 A Okay. Well, let me just - 

4 thiDk-- 4 Q I want to know, why did you think that? 

5 Q Trying to separate out what it is you recall - 5 A Okay. I don’t know what I’ve seen. I don’t knov, 

6 A ButwhatIrecallisthatshe-shestartedinthe 6 whetherthqwerenewspaperarticlesor-Ihad-Iasked 

7 Social Office. 7 theCounsel’sOfficetoletme~ow,after~hadreleased 

8 Q Okay. And one of the phrases you used was “would 8 thedoeumentstotheuewspaper,whattheyreleastd. whether 

9 have.” What is it you understand that is different from your 9 IlookedatsomethingthereorwhetherIlookedatsomething 

0 recollection? IO inthe-thatwasinthepaper,itwouldhavebeenalltlx 

1 A Well, it seems like I have seen something somewhere 1 I same thing. It would have been in that universe. 

2 thatindicatcdthatsheaskedtogetaposition-sheasked 12 They did not bring anything to me and say, ‘Review 

3 me to help her get a position doing volunteer work in the 13 these documents,” you know, as I haven’t reviewed document 

4 Social Office. 14 in preparation for this. That’s what I mean. 

5 And, again, prior to that, I would have thought she 15 Q If I understand what you just said, part of what 

6 wasalmdythere. Thatwasmypemmalxeolleetionofit. 16 you said suggests to me that you asked so- in the 

7 Q What is it you have seen or heard or been told that I7 Cotmsel’s Off& to let you look at what it is they releaxd 

8 has led you to believe that Kathleen Wiley asked you about 18 tothemxiia? 

9 getting a position in the Social Office? 19 A I did, and, actually, they didn’t give it to me. 

0 A I don’t know what it is. Either I’ve seen 20 Q All right. Who did you ask? 

I sometb.ingintbepapersoradocument. Idon’t-Idon’t 21 A Well, I don’t know the -- now, I remember. Kris 

2 know what I’ve seen. 22 Engskov, who is the President’s aide, who used to work in the 

3 Q How reecntly was it that you saw or beeame aware of 23 FVess Off&, brought them to me. And so you might want to 

4 this information? 24 see what they rekased, or what - 

5 A In the last couple of weeks, I believe. 25 Q ~%Ilright. 

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Page 7; 

I A And so my recollection is that the Counsel’s Off&~ 

2 didn’t give them to me. 

3 Q All right. Mr. Engskov, what did Mr. Engskov give 

4 you? 

5 A He gave me a packet of documents, letters, or 

6 whatever they released to the press following the 60 h4inutes. 

7 Q How big a packet? 

8 A How big? 

9 Q An inch thick? 

D A It’s a little less, about a half-an-inch thick. 

1 Q All right_ And how did Mr. Engskov come to giv 

2 you this packet? 

3 A Ithinkheprobablysawsomethingontbenewsand 

4 thoughtImightbeinterestedinitandsortofbroughtitto 

5 me. HeworkedinthePressOfficeforalongtinx. Hegoes 

6 back and forth there and visits his friends then. 

7 I don’t know why. You’d have to ask - you know, 

8 here I am speculating on something. I don’t know why Mr. 

9 Engskov brought it to me. All I know is, he brought it to 

o me. After I had seen it on television, he came and brought 

1 it to me. 

2 Q And I don’t mean this to be - well, 1% just ask 

3 it, really. 

4 A Mm-hmm. 

5 Q He’s doing this out of the goodness of his heart, 

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Page 71 

that, “Gosh, you know, I just think Nancy would like to look 

at these things.” I mean, is that what you’re -- don’t yol 

find that characterization a little odd, that Mr. Engskov - 

that there’s no connection for why he’d bring these things to 

you? 

A I think something was on television already, and I 

think it was already out in the media. And I don’t think it 

was odd. It was perfectly in character for h4r. Engskov. 

Q To bring you a packet of documents about Kathleen 

Willey because Kathleen Willey’s in the news. 

A Absolutely. 

Q How many other times had Mr. Engskov brought you 

documents about somebody who’s in the news? 

A 1 don’t recall that he did it. But that’s - it’s 

not out of his characti. He hasn’t worked for me that long, 

and, if I recall correctly, they probably had my name in some 

ofthoscd ocunxnts. He probably knew that - that my name 

was associated with them in some way and thought I would bc 

interested in them. I think that’s perfectly reasonable and 

understandable. 

Q Did you do anything - maybe I misunderstood you 

earlier, but I thought you said that you asked & Counsel’s 

Office to look at what they’d released. 

A You know, I said that. Then I tried to clarify it. 

I may have asked the Counsel’s Office, but I rememlxr who 

Page= March 31,1998 

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brought them to me was Kris Engskov. 

Q Did Mr. Engskov bring them to you bemuse you had 

asked to look at them? 

A No, he did not - I don’t think that’s why he 

broughtthemtome. 

Q So you asked the Counsel’s Office to look at them 

and Mr. Engskov brought them to you, but you don’t know if 

there’s any conxction. 

A Well, thk iS Why -1feellikeIougJStosayon 

everything afier a while, “I don’t know,” or, “I don’t 

renrmber,” beeause I can’t tell you I asked the c4.Rmsel’s 

Of&e. I said that. Then I thought, no, that isn’t what 

happened My memory is not good. Tbc Counsel’s Office 

didn’t bring those to me. Mr. Engskov b&t those to me. 

Imayneverhave&edtbccoullsel’sofTice. Maybe 

I’mjustsayingsomethingbtcausethatsecmsreasonable. I 

knowIgotapaeketofthat. SoIthough~&no,Ididn’t 

get that from tht couusel’s office. I got that from Mr. 

Engskov. 

Now,I’mtryingtobeashonestandoptnwithyol 

all as I can, and I don’t - you know, you’re twist@ what 

I’m saying around I do not remember asking the Counsel’s 

Office for that. Mr. Engskov brought t&e to me. He 

b~~tthosetom,Ibtlicve-andyou’dbavetoaskhim 

- precisely because my name was associated with ther 

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BY MR. WISENBERG: 

Page b\ 

Q Was that, what, two, three weeks ago? We’re 

talking about two, three weeks ago? 

A I believe that’s when the - they &eased these. 

BY h4R. BARGER: 

Q Did Mr. Engskov bring you these documents after 

they were released to the public or before? 

A Ibelieveittiasaftertlzywererekasedtothe 

public. 

Q AndwhatisyourunderstandingofwhyMr.Engskov 

brought them to you? 

A I think Mr. Engskov probably thought that I woulc 

bcinlu&cdinthansinccmynamcwasassocindtithtbem. 

But I believe you would have to ask Mr. Engskov why 

hebroughtthemtom,bazauseIdon’tbeiievcIaskedMr. 

Engskov why he brought them to me. 

Q Okay. Andthat’smynext quest&. So* Mr 

Engskov brought these to you, what eonvasation did you havl 

with him? 

A I -don’t recall my conversation with Mr. Engskov 

whenhebroughtthemtome. 

Q Did you have a conversation with him? 

A We probably a sentence or two conversation, but I 

don’t recall the conversation. I 

Q Did you ask him why it is he was giving you these 

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I documents? 1 Q AI1 right. And this was a piece of corrcspondenc t 

2 A I don’t redl my conversation with Mr. Engskov. 2 that you had not been able to find previously? 

3 Q Do you recall anything about your conversatioa with 3 A That’s correct. 

4 Mr. Engskov? 4 Q And what else, if anything, did you talk with 

5 A I don’t recall anything of my conversation - about 5 Cheryl Mills about? 

6 my conversation with Mr. Engskov. 6 A Sk indicated to me that they were going to be 

7 Q Wouldthegrandjurybeinetroriftheywereto 7 &a&g c4mspondence or -- I think the day before or that 

8 e4ssumethatitwasjustmrccoinci&nccthatMr.Engskov 8 moming, shortly t&e&outs, but she didn’t get back to me 

9 brought you these documen ts after they became public? 9 or didn’t give me copies of it. 

0 A Well,asIsaidearlier,Ithinkthtrewere 10 Q All right_ So it sounds like you can bracket or 

1 t&vision articles - or television - that they had been 11 pinpoint the approximate date you talked with Cheryl Mills, 

2 released and som&ing was on television. And as I said 12 because, I take it, that your conversation with Cheryl Mills 

3 earlier,thatIthoughtMr.Engskov-buthereIatn 13 is before tlx White House actually releases their copies of 

. . 4D -you’reWkingmetocharacterizewtry 14 the Kathleen Willey cotmspondence. 

s scm&odyelseisgoing~andIthinkit’sunfairto 15 A That’s my recolkxtion of that. 

6 doit. 16 Q Okay. And why was it - perhaps I misunderstoc 

7 But in the interests of sort of moving this along, I7 YOU last we&, but I thought your testimony - strike that. 

8 I would say &at probably Mr. hgskov saw it on television, 18 I take it then that your conversation with Cheryl 

9 sawmylllrmeassociatcdwithi~badbeeninthePressOfCa, 19 Mills-strikethat. 

o ~youknow,secnthistbcrecmdthought,”Boy,Iguess 20 I apologiz, Ms. Hemreich, I guess I’m confused, 

1 Nancy might be interested in this since her name is, you 21 because I thought your conversation with Ms. Mills alsc 

2 know, associated with this.“ 22 concerned a piax of corxespondence Mr. Gecker released thaw 

3 Now, 1 think that makes sense. I don’t recall the 23 the White House did not have. 

4 convasatia~ with Mr. F.ngskov. I did not ask Mr. fhgskov why 24 Q This is now an additional conversation that I just 

5 bebroughtthemtome. AndIthi.nkit’sunfair,inr&ity, 25 tenlembeIedthatIbadwitllMs.MillsthatIhadu’treca.ued 

Page 82 Page 81 

I foryoutoaskmetocharacterizewhybedidit. Ithinkif 1 before. 

2 you want to know why he brought them to me, you should 2 BY MR. WISENBERG: 

3 probably ask Mr. Engskov. 3 Q Let me - I want to interrupt just a second. 

4 Q To the best of your rewhztion, did you ask 4 A Okay. 

5 anybody in the Counsel’s Office to give these documents? 5 Q And I apologize. I want to go back to something 

6 A Icouldhaveaskedsomeone in the counsel’s off-cc 6 that you - I want to clarify something for you, Ms. 

7 togetthoseformt,butIQaotrecallthatIaskedanybody 7 Hernreich. 

8 in the Counsel’s Office to get them for me. I recall that 8 A Uh-huh. 

9 Mr. Engskov is the person who brought them to me: 9 Q If I understood correctly -- and I don’t have a 

0 Q Did you have any conversation with anyone in the 10 photographic memory, so I’m sure this will not be a verbat& 

1 Counsel’s Office about the topic of the Kathleen W&y 11 presentation of an answer you gave a few questions back to 

2 correspon&nce within the last month? 12 Mr. Barger. But I believe you mentioned that sometimes you 

3 A I had a conversation with Chetyl Mills about the 13 snswersarebastdonalogicalinf~ceofwhatmusthave 

4 correspondence, Kathleen Willey correspondence. 14 been. 

5 Q Now, you testified last Thursday, I believe, that I5 I think it’s important that you know we’re assun@ 

6 Ms. Mills asked you about a piece of correspondence from 16 that your answersthatyou’regivingushereaIebasedon 

7 President Clinton to Kathleen Wiiey that had been released, 17 your recollection unless otherwise indicated. If you’re 

8 at least as you understand it, by Mr. Gecker, coirect? 18 giving an answer to a question that’s based on your 

9 A Wait a second. Let’s back up. From - no, no, 19 supposition of what must have logically been, you need to 

D that’s not what I said. 20 make sure you identify that for us for the record. 

1 Q All right_ What is it that Cheryl Mills asked 21 A Yes. You’re right, I should. And I -- and I’m 

2 you - 

3. 

22 afraid I’m not as careful sometimes as I ought to be wit 

A She asked me about a piece of correqxmdence from - 23 that, and it’s very important that I am more careful. 

4 - that’s completely off - from Kathleen w&y to me that 24 Just let me reiterate again that I do hundreds and 

5 had been released by Mr. Gecker. 25 sometimes it feels like thousands of things every day, and I 

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do not remember - it’s impossible to remember. If you sat 

in my offke for an hour or so, I think your bead would be 

swimming, too. 

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There are just -- people -- you know, the phone 

rings constantly, there are people constantly in my door, 

there are constantly people in my outer office, there are 

people, you kaow, going in and out for meetings with the 

President, and it is - you know, in the middle of that, he’s 

saying something, and somebody else has got to do this, and 

somebody else is on the phone and they’re asking you a 

question, you ansuler quickly, and somcrmc’s got slxmtbg out 

tbereand-Imeaqthat’swbatit-auditbappensabout 

that fast. It’s -- sometimes it’s something every five of 

ten seconds. 

Multi-Page”” March 31,1998 1 

i Page 87 

1 A Yeah. Well, I understand, and it’s a point well2 taken,andIwiUtrytodobetterwithmakingsureIclarify 

3 that. 

4 BY MR. BARGER: 

, 5 Q Following up on the Cheryl Mills topic, if I 

6 understand you, you had a meeting with Cheryl Mills before 

7 the Kathleen WiUey ccrrespondence was released by the Whit 

8 House, correct? 

9 A That’s correct. 

1 0 Q And when I say released by the White House, we’re. 

1 1 taIkingabouttbefacttbattbeWhiteHouscreleascdsome 

1 2 pieces of Kathken Willey c4nmqcndmcc after her appearana 

1 3 on 60 Minutes, correct? 

-1 4 A That’s correct. 

1 5 Q Andwhatwasthepurposeofthatmeetingwith 

1 6 Cheryl MiIIs before - strike that. And as you understand 

1 7 it, who was it that released the correspondmce? Was that 

1 8 the White House Counsel’s Office? 

1 9 A I don’t know who released the correspondence. 

2 10 Q What’s your understanding of who released the 

2 !I correspondence? 

2 I2 A I don’t know who released the comqtmdence. 

2 I3 Q My question is, what’s your un&zrstanding? 

2 14 A Well, you’n just asking me to make a supposition 

2 5 again. I don’t know who released the conespondence. 

i Page bc 

1 Q No, I’m not asking you to make a supposition. You 

2 can have an understanding based on what people tell yol 

3 without actually seeing who releases the correspondence 

And for me to remember precisely how things 

occurred - I’m trying to be helpful to you ail, but, you 

know, we may sit beze all day with, “I don’t reca&” and, ? 

can’t tell you precisely,” because that is how my life is. 

Therearetot3manythingsthatgooaevexydayformto 

rtrmember precisely what gces on and how it happened and 

precisely what was said, in what order. 

Andthenforme,ontopofthat,tositt&reand 

gucsswhysorn&odyclscdocssomcthing,andtospcnd~~ 

and-a-half dealing with that - I don’t know why Kris Ehgskm 

brought me that. And, you know - and that’s, again, a 

Page 8C 

I supposition which I tried to make clear to you all. 

2 I’ll try to be helpful. I’m trying to be helpful. 

3 My memory -- 

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Q 1 think we got your point. 

A Okay. I know, but it’s just - 

Q I believe the context was - and everybody knows 

you can remember something and then later on remember 

something else later and say, “Gosh I got that wrong.” 

As a matter of fact, one of the things that we 

typically -- or one of the things that we’ll tell you before 

you leave ultimately -- right before you ultimately leave, 

whenever that is, will be, if you remember something 

differently, to let us know through your attorney. 

A h&n-hmm. 

Q And I think your answer was in the context of 

something you might have said about the Counsel’s Ofhcc 

versus now your memory is Mr. Engskov. 

A h’b-hmm. 

Q My only point is a narrow one. 

A Yeah. 

Q Which is, if you’re giving an answer, if it’s not 

based on your best recollection and it’s based on, ins&ad, 

some logical supposition that you’re making because you 

usually do things that way, you need to make sure you’re 

letting us know that. 

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A I will tell you that Cheryl Mills indicated to me 

that the correspondence would be relcascd. Beyond that, I 

can’t tell yoy you know - 

Q WhatwaUhepurpoSeOfthemeetingwithCheryl 

Mills? 

A I did not have a meeting with Cheryl Mills. 

BY MEL WISENBERG:’ 

Q How did she tell you? 

A Probably - my recollection is that she told me on 

the phone. 

BY MR. BARGER: 

Q Why did you have a phone conversation with her? 

A Idon’tknowwhyIhadaphonecaUwithChexyl 

Mills. 

Q Did you initiate it or did she? 

A She initiated.it. 

Q DidsbeindicatewbattbepurpomofthephonecaII 

was? 

A Ibelieveshejusttoldmethattheyweregoingtc 

be releasing some of the correspondence - releasing the 

Kathleen Willey correspondence. I 

Q Now, you had a second conversation with Cheryl 1 

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1 Mills, I believe, you indicated? You bad two separate - 1 Q Where did you throw them away? 

2 A Later on regarding this - this letter that was 2 A I think I probably threw them in the burn bag. 

3 in--tbatKathleenwiie!y’sattorneyrtleasedthatwastome 3 Q At the White House? 

4 fromba,anditwasa’tinthedoc~tsorthelettersthat 4 A Yes. 

5 I had previously given Cheryl. 5 THE FOREPERSON: Excuse me. when you turned over 

6 Q And your recouection is that that discussion - I 6 UC documa~ts to Bruce Lindsq, did you make photocopis jusr 

7 don’t know if want to say meeting - but that discussion or 7 so you would know what was passed on to Mr. Lindsey 

8 meetingwithCherylMills,thatouXrredaftefthewhite 8 THE wn-mss: No, I didn’t. 

9 House released the correspondence. 9 THE FOREPERSON: Thanks. 

0 A That’s correct. 10 BY MR. BARGER: 

1 Q okay. Andtbatwaswbat-okay. Sopartofwbat 11 Q Going back to the first half of 1993, we were on 

2 you recall today is this other conversatim with Cheryl Mills 12 the tdpic of Katbken Willey begioning to do volunteer work. 

3 reg&ingtbeprerelease-orwhich-ocarrredpre-releaseof 13 Doyourecallwhoitwasbackthenthatwasin 

4 the White House documents. 14 charge of the Social Office? 

5 BY MR. WISHBERG: IS A Yes, I do. It was Ann Stock. 

6 Q Couldyoujusttellus,tothebestofyour 16 Q AndtherewasaConzspcmdenceOffceattbattime, 

7 rec&eaion, sitting here today, what did C%uyl Mills say 17 correct? 

8 to you on the first conversation - the conversation about 18 A Yes. 

9 the release of the - the public release of the 19 Q Doyourecallwhoitwasthatwasinchargeofti 

0 correspondence? 20 Correspondence Office? 

1 A “We’re going to be releasing some of the 21 A Atthattime? Atthebeginn&itwasMarsha 

2 corrcspon~dc or documaits datui ta Kahkm Wii.” And 22 sum 

3 Ithinkshesaidsomethingtotheeffectthat,”I’llgetback 23 Q And after Marsha Scott, who? 

4 to you later about it,” and never did. 24 A We~,therewere&orfouroftheminarow. I 

5 Q Did she indicate to you in any way that this was 25 ~thexewefethreeorfourtbatwwcintherebriefly. I 

Page 90 Page 9; 

I the correspondence that you had gathsed up? I don’t really remember who was after her. 

2 A That was my understanding, but I’m not sure she 2 Q DoyounzznemberwbetherMelindaBateseverwasin 

3 indicated that to me. 3 charge of - 

4 Q Did she reference it as “the correspondence,” 4 A No, I don’t believe Melinda Bates was in charge a 

5 ‘We’re going to be releasing the Wiiey correspondence?” 5 the cmespondence 0ff1ce. 

6 A I don’t remember her exact words. 6 Q whatwassheinchargeof,ifyouxecall? 

7 Q Are you aware of any Willey conespondence gathered 7 A She’s always been in charge of the Visitors’ 

8 - pardon me for pacing - are you aware of any Willey 8 office. That’s the office that handles tours and some 

9 correspondence gathered other than what you and your 9 events, like the Easter Egg Roll. 

o assistants had gathered? 10 Q DoyourecallhavingameetingwitbKatbleenWiUey 

1 A I think they found things in Records Management 11 in approximately April of 1993 at the White House? 

2 that I didn’t gather. 12 A Idon’trecallhavingameetingwithKathleen 

3 Q Did Ms. Mills tell you that during the conversation 13 Willey in April of ‘93. 

4 with her or have you subsequently learned that? 14 Q Well, do you -andIdon’tmeanti-Idon’twan 

5 A I have subsequently learned that. 15 to play words here. Do you recall any meeting with Katblem 

6 h4R. WISENBERG: That’s all I have on that point. 16 W&y in, you know, the early part - in the first six 

7 BY MR. BARGER: 17 monthsof 1993 inconnectionwithbaattanptingtogeta 

8 Q Going back to the firs half of 1993,I was asking 18 volunteer position at.ti White House? 

9 you Sony questions about - I take that back. Before I get 19 A I recall a conversation with her about - moving 01 

0 there, tbe packet of materials that Mr. Engskov gave you, 20 here, about getting a better position in the Social Office, 

I what did you do with those? 21 or taking on more responsibility in the Social Off&. But 

2 A Ithrewthemaway. 22 tbat’s tbe only kind of conversation that I remember at that 

3 Q Didyoureadtlxzmfirst’? 23 time, in that period of the first year or so. 

4 A Oh, yes. I lookedthroughthem. I’mnot sure I 24 Q Do you recall whether the President of the United 

5 readthemindetail. Iglancedatthem. 25 States gave you any instructions or discussed with you 

Page 89 - Page 92 
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Page 93 

anything having to do with Kathleen Willey getting a 

position, a volunteer position at the White House? This 

would have been, again, in approximately - in the fvst six 

months of 1993. 

A Do I recall the President asking me to -- rephrase 

that, because I’m not sure what you’re asking me. 

Q I’m trying to figure out how it was that Kathleen 

WilIey came to get a job at the White House. ‘Ihat’s what 

we’re trying to figure out 

A Sure. What job are you talking about? 

Q Any job. Let’s pick the first job. How was it she 

cametogetajobattheWhiteHouseinthefustplace? 

A Are you talking about a volunteer position? 

Q Volunteer position. 

A I don’t know how she came to get a position - a 

volunteer position in the White House to begin with. 

Q Do you know whether the President played any role 

in her obtaining a volunteer position at the White House? 

A I don’t know if the President played any role in 

her getting a volunteer position at the White House. 

Q Do you recall the President ever discussing with 

you anything about Kathleen Willey getting a volunteer 

position at the White House, either assisting Kathleen Wiliey 

or contacting Kathleen WiIley, setting up a meeting with 

Kathleen Willey, anything like that? 

Multi-Pagem March 31,1998 I 

, Page 95 

1 Q Having had that conversation, does that refresh 

2 your recollection in any way about having, in fxt, met her? 

3 Do you understand my distinction? 

4 A It - recalhg the conversation and tlxn having 

5 met her? Yes, it does help, yeah 

6 Q Okay. Well, putting aside the question of the 

7 phone number - 

8 A hh-itmm. 

9 Q - do you mcaIl meeting Kathleen Willey at the 

1 o Richmond airport? 

1 ,l A IdorecallmeetingherattheRichmondaixport 

1 .2 Q Do you d at some point later, periraps in 1993, 

1 3 having a conversation with her that, in part, included the 

1 4 facttha&youknow-wordstothceffectof,”WcI&wemet 

1 5 at the Richmond airport”? 

1 6 A Irecallthatwehadaconversationaboutthat. 

1 7 Q Al.l right. I’m going to stay in 1993 for a little 

1 8 bit. DoyourecalIKathkenWilleyin1993talLngwithyou 

1 9 aboutlxzrdesiretoworkintheSocialOff&? 

2 !O A No, I don’t recall a conversation with lxx about 

1 !I herdesimtoworkintheSocialOffice. 

2 !2 Q Is it possible -andwe’lIgoftutherdownthe 

2 13 continuum Is it possible that the President asked you to 

I 2 !4 assist Kathleen Wllley in getting a position_ a volunteer 

2 !5 position at the White House in or about April of 1993” 

Page 94 

A I don’t recall him ever having a conversation with 

me -- I don’t recall a conversation with him about getting 

Kathleeu W&y a volunteer position. 

Q I asked you some questions last week about whether 

thee Governor Clinton asked you to get Kathleen W&y’s 

phone number at the Richmond airport in approximately the 

fall of 1992. Do you remember that topic? 

A Yes, I do. 

Q Do you recall meeting with Kathleen Willey in or 

about April of 1993? 

A I don’t recall meeting with Kathleen Willey in 

April of 1993. 

Q Do you meal1 meeting with Kathleen Willey and 

having a discussion or talking about or recollecting or - 

I’mtryingtobegeneraibansotbatwedon’tfalIthro~ 

the cracks -- about the fact that you met Kathleen Willey at 

the Richmond airport in the fall of 1992? 

A Do I recall having a conversation -- meeting with 

her at - let me - you seem to have said two or three things 

there, so -- 

Q Did there come a point when you and Kathleen Willey 

had a conversation about the fact that you met Kathleen 

Willey at the Richmond airport in the fall of 1992? 

A I believe that we had a conversation along those 

lines. 

Page Ll. 

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2 tomakewas,giventhefactthattlxywereatleast 

2 participants in the ‘92 campaign, I take is it was not I 

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A It’s possible. 

Q And as you testified earlier, at least from a 

umversation - one or more conversations you’ve had with th 

P&da, the President viewed Mrs. WiIley and her husband 

as valuable assets in the 1992 campaign. 

A Rephrase that? Because you said two or thtee 

thingstlxre,too,thatIwanttomakesurethatQ Idon’tknowtheexactwordingyouused,butthac 

wasapoint-atsomepointyouhadacoavasatioawitbtbe 

Prtsidentwhaehe-Idon’tlrnowtherightwadshat,but, 

basicaUy,hewasawarethatKathlecnWilleyaodherhusband 

had assisted in his 1992 campaign. 

A Ithinkyouhadaskcdmethat-youk~~~,wbctbcr 

itwasmyun~thattheywerevaluab~youkrutw-- 

ortheyhadpatticipatedinthecampaignandinwhatwayand 

whereIgotthatfrom,andIsaid,youknow,fmmher,andI 

believe the President as well valued what &y had done. 

Q Okay. 

A So that is rephrasing that and saying - 

Q That’s all 1 was trying to get at. 

A y&Yes. 

Q Andmyonlypointwas-thepointIwantedto _ 

unusual for Kathlazi W&y, given her and her husband’s I 

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Page 9; 

assistance to the campaign, to get a job as a volunteer at 

the White House. 

Is it fair to say there’s nothing unusual about her 

getting that position? 

A 1 think that’s fair. 

Q Okay. ‘That’s all I - that’s the only point I was 

hying to make. 

A Okay. 

Q Your undtrstanding is that sht at some point - 

perhaps she bad an earlier position, but at some point sbe 

bazar~~ a voluntax in the Social Off& working for Ann 

Stock? 

A That’s correcL It’s my understanding that she had 

that - she was a volunteer in the Social Office. 

Q Turning your atteotioo to approximately the sunmxr 

of 1993, you were talking ahout the Presideot’s vacation in 

1997. 

A bhhUXf~. 

Q DoyounxallthePresidentandMrs.Clintontaking 

a vacation in the summer of 1993 in Vail? 

A Oh, well, I wouldn’t have been able to pinpoint th 

time, but they at some point went to Vail - 

Q Allright 

A -- in the last, you know, five years. 

Q AlI right_ Do you recall Kathleen WiIIey 

Multi-Page” March 31,19

1 Pag

1 President on Novanba 29th?” I’m asking you wbctk. around 

2 that time period, you recall Kathleen Willey asking you i

3 shecould--thatsbeneededtomeetwiththePresident,or 

4 asking you if she could meet with the President? 

5 A I -- I don’t recall the specific incident of her 

6 asking to meet with the President, no. 

7 Q Obviously, given her position as a volunteer, i

8 fair to say she couldn’t just walk in and see the Presiden

9 she would need to clear it with somebody? 

I IO A That’s correct. 

I 11 Q All right. From your experience, generally, if 

I I2 KathkmWiiwantaitonrctwithtkRsidar~whowould 

I 1 13 shechcckwithto~ifitwouldbeallrigbttomeetwith 

I 14 the President? 

1 I5 A She’d check with me. 

1 16 Q SoifshedidhavcameetingwiththePresidenton 

1 ,7 that day, the likely person she would have checked with t

1 88 get permission would be you. 

I .9 A That’s CQlTCCt. 

2 !O Q And just to clarify here, do you recall whether 

:2 !1 arrangadorwhcthcrshcaskcdtomttwiththcPrtsidcntthat 

2 !2 day? 

2 !3 A Not that day. I don’t recall anything related to

2 !4 you know, this specific incident. 

2 !5 Q Okay. Assumingshemetwiththel’residentonthat 

I Page 

day in the afternoon,, do you recall seeing Kathleen Wille

leave the Oval Office after meeting with the Presiden

B A No, I don’t recall seeing her leave. 

Q There have been akgathS or various media 

reports, depending on who you believe - 

A bhhI’Kn. 

Q -- that she was disheveled, or her lipstick was 

smea14, or her blouse may have been disheveled, for wan

better terminology. 

1 Mm-hmm. 

1 Do you recall seeing anything like that? 

1 No, I don’t recall seeing anything like that. 

1 BY MR. WISENBERG: 

1 Do you think that’s something you would remembe

1 IfIsawit,IthinkI’drememberit. 

1 BY MR. BARGER: 

1 Generally, do you recall how Mrs. Will9 dres

1 Generally, yeah, I do recall how she dressed. 

1 Okay. And what I was sort of smiling at to myself 

2 

2 

2 

12 

2 

2 

Page 98 

volunteering bu and her husband’s condominium to any of tk 

WhiteHouse-OrtopeopleintheWhiteHousestafi~o 

might be accompanyingtheResidentiftheynctdedaplacetr 

StayinVailduringthatsummer vacation? Doesthatringa 

bell? Do you recall any of that? 

A No, I don’t recaII any of that. 

Q Do you recall the President asking you to obtain 

the Wikys’ Vail phone numba in case tbcy wanted to contact 

the WiIleys on their summer vacation? 

A No, I don’t recall him asking me for their phone 

number. 

Q If he did, that would not have been particularly 

unusual, would it? 

A I don’t think it’s unusual, no. 

Q Now, there came a time 011 or ahout November 29th of 

1993, which is the date that is associated with the alleged 

incident between the President and Kathleen Willey - 

A Is that what you’re saying, that that’s the date -- 

Q That’s the date - 

A - of the alleged -- 

Q -- November 29th, correct. 

A h’fm-hmm. 

Q And my question is, do you recall Kathlm Willq 

askingyouifshecouldmcetwithtbeRtsidentonthatda)/! 

AndIdon’tmcantosaysheaskcdyoy”CanIm&twiththt 

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is, I don’t know if my wife would - a man might no

appreciate that, although I’d probably get in trouble 

saying that, too, but perhaps a woman would be mom like

rcmank-andImcantba~inapurclytxmplimcntarywayA (Laughing) You’re treading very lightly. Mos

women in here, I think. 

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Page 101 

MR. BARGER: ?he record shouldreflectwewereall 

laughing. 

BY MR. BARGER: 

Q Gmerally, do you recall how she dressed? I 

thought you said yes. Could you elaborate on that? 

A Well,Irccall-herclothesseemedtobe 

expensive - 

Q Okay. 

A -- is one thing I remember about her. 

Q Generally dressed appropriately for the office in 

which she worked? 

A Yes, she did dress appropriately. 

Q ck?nerdlydreSseS? 

A Dresses or suits. My recollection would be more 

that she wore suits. 

Q Okay. Do you recall, because this date has been 

bandied about some, this November 29,1993 date. 

A hh-hmm. 

Q Doyourecall-andp&tpsyoubadanopportunity 

to look - to refresh your memory, et cetera - do you recall 

whether or not the President had any type of meeting or 

specifically perhaps a cabinet meeting the afternoon of 

November 29,1993? 

A No. No, I don’t recall that. 

Q Have you taken any steps to tty to figure out what 

Multi-Pagem March 3 I,1998 1 

Page 103 

1 having asked to see the President very shortly before it 

2 turned out that kr husband had killed himself? 

3 A No, I don’t recall that she had asked very shortl: 

4 before he killed himself. 

5 Q And you don’t recall any unusual incident 

6 whatsoever involving her, how she acted or looked wheo she 

7 left a meeting in tk Oval Office with the President; is that 

8 correct? 

9 A That’s right_ I don’t recall -- let me make sure I 

1 IO undemtood you correctly. That -- you’re asking basically 

I II aknostthCSamthin&thatsht--waStbercallythingUnusual 

I I2 ahout how she looked or anything that would mayhe help me 

I 13 remember it, or specificaIly - 

I 14 Q With respect to any of that, in the history of your 

1 15 time at the White House, do you mcall anything unusual aboc 

1 16 KathkmWillcy-myoceasionwixnKatbbenWilleywodd 

1 17 havelefttheOvalOfficeamaafterameetingwiththz 

I I8 President, anything unusual? 

1 19 A I-you’naskingmew&&erthcwholetimeI’ve 

1 !O workedthere,ifIrecallanythingunusualfollowingatime 

2 !l Kathleen Wiey would have left the Oval Office, something 

1 !2 that would -- 

2 !3 Q Right. Anything ~usual about anything she looked 

1 !4 Iike or said or did upon leaving the Oval Office. 

2 !5 A No, I don’t. 

Page 1& 

1 BY MR. BARGER: 

2 Q I was going to ask you some questions along 

3 the lines of the meeting that apparently took place on 

, 4 Novembcr29thintamsofhowlongshtwasintbtOval 

5 Office, but I take it you don’t recall that meeting. 

6 Is that fair to say? 

7 A That’s Correct. 

8 MR. ELUtGER:‘ okay. so we’ll tip those questions. 

9 MLWISENEIERG: LtttberecmddeCtthatUnwill 

1 0 get a knock when lunch arrives. 

1 1 BY h4R. BARGER: 

1 2 Q Doyouredthattberec8meatimewhmhttdam 

1 3 Willey’s husband committed suicide? 

1 4 A Yes, I do mmemberthatthzrewasatime~- 

1 5 Idommemberthattime. 

1 6 Q Okay. Accept for the purposes of - that tht date 

1 7 of that was on or about November 29,1993. Do you recall 

1 8 having any discussion or conversation with the Presideni 

1 9 about Kathleeo Willey’s husband’s death? In other words, 

2 0 did the President ever talk with you about the fact that 

2 ,l Mrs. Willey’s husband had died or committed suicide? 

I2 2 A Yes,kdidtallctomeahoutherhushandcommitting 

2 3 suicide. 

2 4 Q Doyouremem berwhenitwasinconnection-in 

2 

Page 102 

I the President’s schedule was that day or reviewed any 

2 documents, or has anyone had any dimussions with you ahout 

3 the events of that day to either refresh your memory - what 

4 I’m trying to get at is whether you’ve looked at anything 

5 that would make you aware of whether the Resident had a 

6 meeting in the afternoon of that day. 

7 Q What kind of documents are you talking about? 

8 Q You know, since I’m not familiar with the White 

9 House -- 

0 A h4rIVhxllxtl. 

1 Q -- I don’t know what would be available to you. 

2 ButallI’mtryingtogetatiswhetha,havinglookedat3 or talked with anyone, whether you 8re aware of or whether 

4 you have any understanding of whether the President had a 

5 meeting scheduled for that afternoon. 

6 A No, I don’t know anything about a meeting that 

7 afternoon. I haven’t looked at anything to refresh my 

8 memory. 

9 MR. WISENBERG: Let me butt in for just a second 

0 MR. BARGER: Yes. 

I BY MR. WISENBERG: 

2 Q MI. Barger is asking you a lot of questions about e 

3 specific date, I think November 29, ‘93. 

4 A hhdm.tn. 

5 Q Let me ask you this. Do you mall Kathleen W&y 5 cmimction - in relation to Mr. WiIley’s death? Was it a I 

-. .-_ .- - ^ - I___. __, __^^ 

Page 101 -Page 104 
1385 

Multi-Page= March 31,1998 

Page 105 Page 16

1 ~nversation you had fairly close in time after the death, I retuned to the White House after her husband’s death’? 

2 alongtkeafterthedeath? Usingtbedeathasabenchm& 2 A What period of time? How much time are you talkng 

3 when was the conversation with the President? 3 about? 

4 A It was a pretty long time after. May I just 4 Q Approximately ten to fifteen days after her 

s expand a little bit on this. 3 I don’t recall any specific 5 husband’s death 

6 conversations that I had with the President during that 6 A I don’t recall that specific meeting nor would I 

7 time or shortly thertafter, although I feel certain that I 7 have been able to say that it was that soon at all. 

8 probably told bim about it bceau~ people I think bad told 8 Q Do you recall after she came back to the White 

9 me,maybesomeo= inthecounsel’soffice-ornotcouusel’s 9 Houaeafterberhusband’sdeath,doyourtmllwhetbersheo offict, maybe one of kr friatds, I don’t know who told IX., I lo do you recall her meeting with the President after her 

I &.m’t rexAl who told me, for all I know, Kathleen could have 11 husband’s death? 

2 called and told me. But I don’t rcmtmbcT that. But I feel 12 A No, I don’t recall her meeting with the President 

3 like I was probably the one who told him that her husband bad 13 after her husband’s death. 

4 died. 14 Q Do you recall whether she had any conversations’ 

5 Now, again, someor~ could come and say “I’m tk one 15 with tbc Resicknt about obtaining a paying job at tbe White 

6 who told bim end I’d say, “Fm I agree with you,” but that 16 House after her husband’s death? 

7 is my general recollection. 17 A Say that again. Do 1 recall wbzthzr she had any 

8 That’s to say that for follow-up questions, I don’t 18 conversations with the President? 

g know that specific couversaticm, but I just want to be clear 19 Q&m 

10 that we probably did have a conversation in that period of 20 A About- 

!I time about it. It would have made a lot of sense and I’ll 21 Q About getting a paying job. 

12 just make that clear for the record, that I don’t have a 22 A No, I don’t recall whether she had any 

3 specific memory, but 1 feel like we probably did. 23 convusations with the President about that. 

‘4 A JUROR: Just a quick question. 24 Q Did the President ever - after Mr. Willey’s death 

5 THE WITNESS: sure. 25 did the President ever say anything to you about the topic of 

Page 106 Page 10

1 AJUROR: Inacaselikethis,wouldtheWhite 1 Katbkn Wiley getting a paying job at the White House? 

2 House have sent flowers or some sort of condolence? 2 In other words, what I’m trying to get at is did 

3 THE WITNESS: Well, not my would we have 3 the President have any conversations, did the President 

4 sent flowers. Sometimes we-infact,veryrarelydowe 4 wrpressrmintertstinhclpingher,didhe~waninterest 

s send them in Washington. More often they send them in s in assisting her getting a job, helping out because of tk 

6 Arkansas, but it’s interesting because just how - it’s a 6 death of her husband, that kind of thing? 

7 long complicated story about the people in Arkansas am 7 A At some point, and 1 can’t tell you exactly when, 

8 people who always did that for him when be was governor and 8 eqxcklly in relation to her husband’s death, the Resident 

9 tbey’veassumedtbatroieandstayedinArkansasanddotbat, 9 indicatedanintere&inbelpingbcrgetajob,apayingjob, 

o but it’s not something we commonly do in Washington. 10 a job. 

1 AJUROR: Thank you 11 Q Was this more than one conversation? If you 

2 BY MR. BARGER: 12 xtxall. 

3 Q Doyou~afterEdWiky committed suicide, do 13 A I don’t recall. 

4 yourecallwhethertbaceameatimcwknKathleuiWiIley 14 Q What, if any, role or what, if any, efforts did 

5 cxpresscdanin~inobtainingapayingjobatthtWhite 15 youtakttohytoassistMrs.Willeyingdtingaposition, 

6 House? 16 a paying position, at the white House? Did you play any 

7 A Yes. I recall her interest in obtaining a paying 17 part in that, any role in that? Did you assist her? 

8 job. 18 A Well, 1 know that I SpOkt with tk OffiCe Of 

9 Q Do you recall whetlmzr approximately -- do you 19 Presidential Personnel about assisting her in getting a 

0 rtcallwhetherKathlctnWilleycametoseeyouaftashe- 20 paying job. 

1 in other words, her husband commits suicide, them’s a period 21 Q Do you recall who would have been in charge 

2 of time where she takes leave and doesn’t eomc to the White 22 of Presidential Personnel? And if that changed over 

3 House,doyourecallaftersbe~backtotheWhiteHo~ 23 time? 

4 thatshecamcintosctyouandmttwithyouintht-well, 24 A we& my rezoktion of conversations I had 

5 I’ll just leave it at that that she met with you after she 25 u~ert with Craig Smith, who was in charge of personnel for 

___ - _ ^

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Mr. Smith about and what did you say to him? 

A My general ~fle&On iS that She was mtcrtsttd 

in a position and were there any available in government and 

could he assist her and that this was something that tht 

President would like to sx done as well as I would like to 

see done. 

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25 her to be a reliable, trustworthy worker at the White House? 

Q And the fact that you would like to see it done, I 

think we’ve covered this a little bit before, but during this 

time period, you considered Mrs. Willey a friend. 

A I did consider her a friend. 

Q Was she a social friend? In other words, did you 

all go out together? Or was she a friend only in the context 

of you worked together? 

A We worked @ether and my recollection is that she 

would come in on the train and go back to Richmond, SO WC 

takeA about going out to dinner, but I think she generally 

wouldgohomcintbccvahgs. MyworlcboursarcsuchtbatI 

don’t have a whole lot of time to socialize. 

Q And when you say “go back to Richmond,” as you 

unda%ood it she was commuting lkorn ha bomc in Ri&mond. 

A Yes. My recollection is she took the tram up 

here. 

Q Now, during the time that you worked with her 

and you developed a f&n&hip, did you gcnually consider 

I 

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Q And after Craig Smith, do you recall who took 

over from him? Was that Bob Nash? 

A Bob Nash, I believe, took over from Craig. 

Q In any conversations that you had, did you convey 

the fact or convey information that the President was 

supportive of Mrs. Willey trying to get a paying position? 

A I believe I conveyed that to people. 

Q And, again, from your perspective, nothing improper 

about the President assisting Mrs. Willey and nothing 

improper in you assisting Mrs. Willey. 

A That’s eorreet 

Q Do You remember - was there any discussion about 

where in the White House Mrs. Willey could possibly work? 

What kinds of positions, if any, were you trying to get for 

her or were you trying to see were available? 

Did you have any particular area in the White House 

you were looking or - 

A No. Well, I’m sorry. I should let you finish 

Q That’s all right 

A No, I didn’t have any specific ideas about a 

place in the White House for her to work. 

Q As best you meall, generally, what were 

your conversations with Craig Smith about with regard to 

Mrs. Willey? I mean, generally, what did you talk to 

Page 110 

a while. 

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Page 111 

A I had nothing to judge that or base that on. 

Q I’m sorry. Based on your dealings with her, you 

had no opinion -- 

A We& you’re asking me about a worker and 1 didn’t 

deal with her on that level. I didn’t deal with her as a 

worker. 

Q Well, how about just in the context of the eontact 

you had with her, as a friend, a friend who you saw at the 

White House but really didn’t have the opportunity or didn’t 

take - nothing pejorative, you didn’t socialize outside ot 

work, but in the context of your contacts with Mrs. Willey, 

did you find her to be a reliable, trustworthy person? 

A Well, again, let me just say probably the only 

context I would have that to base that on, if she told me 

“I’~cwrtsaeyouin3omin~“thcnsbemightshowupin 

30 minutes. But for me to say beyond that, she didn’t work 

formeandsoIhadnothingtobaseitonifshewas--you 

asked me reliable, trustworthy worker. 

QRigh 

A She didn’t work for me, so I would not have 

anything to base that on. 

Q 1 take it, though, if you had felt she was not 

qualified or she was not reliable or was somehow a threat 

to the White House, you wouldn’t have been willing to assist 

tier in getting a position time? 

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A She seemed to be intelligent She indicated to m 

thatshewaseapablcandtbatskhaddonealotofthings 

and she indicated that she - you know, wanted sonic help. 

And I, frankly, would leave it to other people to make tbc 

determination of whether she was qualified and they could 

cbcck into her background and I could make the recommcndaticu~ 

andsaythisissomebodywbohashelpedtbeRsidentalot 

andhewouldliketosatushelpher. Youknow,Idothis 

forpeople. Butthentakeitfrwntkreforsomumeelseto 

look into her work record and &ermine if she’s a reliable, 

trustworthy worker. I liked her personally and because 1 

liked her personally I wanted to help her. 

Q And, in fairness, I’m not asking you to pass on 

the tru&fulness or untn~tMuIness of thz allegations that 

are out there about the November 29th incident 

Doyoureeall-didthereeomeatimewhen 

Mrs. WiIIey did get a part-time paying job at the White 

House? 

A Therewasatimethatshedidgetapart-time 

paying job. 

Q Do you remember for whom it was she worked? 

A She worked in the counsel’s offree. 

Q Do you recall whether she worked for Mr. Cutler? 

A ~thhkitWaSh’f.r.ht.k 

Q Anddidttxzreeomeatimethatherpositioninthe 

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counsel’s office - 1 don’t know what the right word is, 

terminated or ended? 

A Yes. There was a time that her position - 

Q Do you recall whether that occurred about the tim 

that Mr. Cutler left and Judge Mikva replaced Mr. Cutler as 

White House counsel? 

A Well, I don’t recall the specific timing of it, but 

it’s my understanding that that was the time. 

Q Okay. At least as you understand it, that’s about 

tMiIDCp&dtbatMrs.Will~Leftbtrpart-timcposition 

in the counsel’s Off&? 

A Yes, that’s my understanding. 

MR. BARGER: Ah right 

I notice there’s been no knock on the door for 

lunch yet. 

rrin FoREpERsoN: I know. I’m almost worried_ This 

is something that’s not normal. 

MR. BARGER ‘Ibat Mr. Wise&erg has left to eat the 

lunches? Is that it? 

TEE FOREPERSON: Well, I could hear his stomach 

over here, so - 

(Laughter.) 

A JUROR: We still need a break. 

TEE FQREPERSON: No, I think somebody ought to 

:s check. 

Page 114 

1 MR. BARGER: til right. 

2 THE FOREPERSON: Let me go check. 

3 MR. BARGER: m right. 

4 THE WlTNESS: What time is lunch usually? 

5 MR BARGER: Usually 12:30 and it’s oue now. Yes. 

6 TEE -s: Do they bring it from downstairs? 

7 MR. BARGER: For the jurors. Not for us. 

8 We’re still on the record. One of the jurors has 

9 left, but we still have a quorum, correct? 

0 TEE DEPUTY FOREPERSON: Yes. 1 think the juror! 

1 would like to break anyway. 

2 MR. BARGER: All right. krmission for the witness 

3 to be excused? 

4 THE DEPUTY FOREPERSON: Yes. 

5 MR. BARGER-. til right. 

6 Thank you, Ms. Hernreich. We’ll break until -- I 

7 don’t know. 

8 Whattimeareyou9 A JUROR: Well, it depends on when lunch comes. 

10 MR. BARGER: All right. 

!I THE wlTNE!ss: You’ll let me know? 

:2 MR. BARGER: We’ll let you know. 

13 THE WITNESS: ~‘11 wait out there for you. 

!4 (The witness was excused at 1:OO p.m.) 

!5 l **** 

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Whereupon, (4: 13 p.m.) 

NANCY HERNREICH 

was recalled as a witness and, having heen previously duly 

sworn by tk Forepemon of the Grand Jury, was examined 

testified further as follows: 

EXAMINATION (RESUMED) 

MR. WISENBERG: Let the record reflect that the 

witness, Ms. Nancy Hemreich, has reentered the grand jury 

room. 

We have a quorum and there are no unauthorized 

persons, correct? 

m FOREPERSON: We have a quorum and tkix arc n

unauthorized persons. 

MR. WISENBERG: Okay. Go ahead. 

THE- ShehastoremindmeI’mstilltmder 

oath. 

THE FOREPERSON: Yes, you are still under oath

TEE WJTNESS: Thank you. 

MR. EMMICK: First let me apologize for the dela

that sometimes things are just beyond our control. Let’s try 

to do what we can in the 15 minutes that we have left. 

BY MR. EMhECK: 

Q What I would like to do is turn our attention to 

?4 one of the things that we had talked about a bit ago a 

15 that was your earlier search for books at the request c 

n

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Mr. Kendall. 

A Okay. 

Page 

Q And as you wen describing that, it occurred to 

that I didn’t have a picture in my bead of where you were 

looking and that further reminded me that I don’t evcn knc 

whatitemsaieinthevariousroomsthatwe’retalkingabol 

And so what I’d like to ask you to do is turn your attention 

toadiagramthatIhaveinaveryrudimentaryfsshion~1 

Can you see this reasonably well? 

MR. WISENBERG: Mr. &xnnick? 

MR. EIviMICK: Yes? 

(Pause.) 

MR. EMMICK: We apologize for the trouble. If 

could ask you to leave and we’ll have the other pa-son con 

back in. 

(The witness was excused at 4: 15 p.m.) 

****I) 

Whereupon, 

NANCY HERNREICH 

(4:22 pm.) 

was recalled as a witness and, having been previously duly 

sworn by the Foreperson of the Grand Jury, was examined 

testified further as follows: 

EXAMINATION (RESUMED) 

THE WlTNESS: Try again? 

MR. EMMICK: Yes. Since I’ll be asking you to 

m

I

li

n 

w

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stand, you might as well stand. 

MR. WISENESERG: Let the record reflect that 

Ms. Hemreich has entered the grand jury room. 

THE FOREPERSON: Ms. Hemreich has entered the 

grand jury room. ‘here are no unauthorized people and we dl 

have a quorum. 

Ms. Hernreicb, you are reminded you are still under 

oath. 

THEwrl?%ss: Yes. 

MR J3lMrcx: I mentioned to you earlier that one of 

the things I wanted to do is take a look at a rudimentary 

diagram of tht Oval Office, your office, the study, the 

diningroom,tbebathroomandtbepantry. F~that’swbat 

1 have attempted to draw here. I don’t purport to be an 

enginazoramasterdraftsman,butwhydon’twejuststart 

off by calling this -- Iguessitwouldbe-thenext 

exhibit would be NH-I. I don’t think we have labelled 

others. Do you know? Not today. All right. Let’s just 

call this - 

(Grand Jury Exhibit No. NH-I was 

marked for identification.) 

BY MR. EIUMICX 

Q Let’s just start off, how bad is my diagram? 

A It’s remarkably good. You missed a few doors, 

but -- 

Page 118 

I Q All right. 

2 A -- but it’s still remarkably good 

3 Q All right. We’ve marked it there as NH-I. Which 

0 are the doors that I’ve missed? And we’ll use a black pen to 

5 mark the doors. Go ahead. 

5 A There are a couple of things, I think. The only 

? thing is the bathroom’s not that big, so I would have the 

5 bathroom about right there. 

3 Q 

) A 

1 Q 

1 A 

1 Q 

I A 

i Q 

i A 

I Q 

1 A 

All right. The bathroom is there? 

Okay. And there’s a door to the bathroom. 

That would make some sense. 

Mm-hmm. 

The door goes in? 

No, I don’t remember. 

All right_ We’il make it like that. 

Okay. There’s a door here. 

Okay. It goes in? 

I think so. I don’t pay attention to those kinds 

1 of things. 

I Q Okay. 

A There’s a door about right here. There’s a door 

: ha-e. 

Q All right. 

A Them’s a hallway by those offices -- I think 

that’s all the doors. 

Pagem March 31,1998 

Page 119 

I’ll give you a pen if you feel comfortable -- 

I’m not - 

1 Q Okay. 

2 A Oh,there’sadoortothepantry. 

3 Q That makes sense. All right. We& let’s as a 

4 firststepintheprocess,canyoutelluswherethe 

5 furniture is in the oval office, in the study and the 

6 diningroomsothatwehaveapictureinourmindsaswe 

7 sort of put things there? 

8 A Okay. 

9 Q 

.O A 

.I Q 

.2 A 

3 Q 

4 A 

5 Q 

6 A 

7 Q 

8 A 

9 Q 

:O A 

If you want, you can point and I’ll draw. 

Okay. This is the President’s desk in here. 

I’II draw that. I’ll draw a desk. Okay. 

And there is a table behind his desk. 

A credenza type table? 

Yes. A c&enza table. 

A credenza A desk. Okay. What else? 

Thexe’satablehenthathassomedrawersinit. 

Okay. I’ll just - 

Andthenthzre’satableoverhere-Ithink 

:1 that’s what you’d call it. It has drawers in it, too. 

:2 AJUROR: Au’edex.ua? 

:3 THE wrrmss: Pardon me? 

4 AJUROR: Acrtdenza? 

5 THEi WlTNES: It’s a credenza. I think it’s got 

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drawersinit. Onthetopofthetable,ithasabustof 

Rodin’s 7be Tbinkc? and that’s what you really see or pay 

attention to and above that is a picture of tht American 

flag. ThosearetbehvotbingstbatKallystrikeyouabout 

that particular table, is tlmz Rodin and the painting above 

it. 

BY MR. EMMICK: 

Q what eke is in the tid office? 

A Well, here there is a small table with a Frederick 

Remington sculpture on it. 

Q A table? 

A &dmm. 

Q Okay. 

A Andthere’saeouchbzreandacouchhere,faeing 

5 eachother. 

6 Q Facing couches? 

7 A Mm-hmm. There’s an oval table between them. 

B Q All right_ Well, it will work. Okay. 

3 A Two arm chairs here with tables on either side of 

1 tbem,kindofbawantbecouchandtbearmcbairs,youcan 

I get people on either end. 

2 Q h’s a table there and a table there? Somethi. 

3 like that? 

1 A Yes. 

5 Q Allright. 

Page 117 - Page 120 

_- -c ._ - I - S^s.^. _^_ _^__ 
1389 

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Page 121 

Of course, there’s a fqlace here, a mantel. 

Okay. A fireplace. 

Mm-hmm. 

Allright. 

The built-in bookcases - here. 

Bookcases? 

Mm-hmm. 

Okay. 

So this table is probably right about here, because 

these are bookcases, buih-in bookcases, and the table is 

beyond that. 

Q Okay. 

A Built-in. 

Q Okay. 

A And-let’ssee. Seemslike-Ithinkthebusts 

are on the firtplace. I don’t really rememberiftlEre’s 

anothertablewithabustonit. Tbereanszveralbustsin 

henz. There’s a table in front of this bookcase. 

Q Okay. 

A That’s a low tabk that has some items on it. 

Q Okay. 

A And then along the wall, you probably don’t have 

enough room bzre, there are a few sort of straight back 

wooden &airs. lbcrt are probably two along here, maybe, 

under the bookcases, two along here. 

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Q They would be loose chairs? 

Page 122 

A hOseChairs. 

Q Ah$jht. 

A Twohere,twohm,oneoneithcrsideofthedesk. 

That’s minimally. There might be four in each of those 

places, I don’t remember. 

Q Chair-chair-chair-andwe’llputcfor 

chair. 

A Then might be a couple more chairs in there. 

They’re small, movable chairs. And there are some on either 

side of the desk. 

Q Okay: 

A Okay. That’s about it. I might have missed a 

few - that’s generally it. 

Q Okay. What-about in tht study? What is there in 

ttie study? 

A There’samckingchairhcn,rightaroundinhere. 

Q Let’s Cal] it - we’ll call it RC for rocking 

chair. Okay. 

A There is a sort of a table there, like a credenza, 

something like that. 

Q Credenza Okay. 

A There’s a desk over here that’s small and that’s a 

deskthatQ A roll top? 

i Page 122 

1 A It’s not a roll top, it has a top that lifts up and 

2 down and it opens. It looks like a table when you’re looking 

3 at it. It doesn’t really look like a desk particularly. 

4 Q We’ll call it table. Okay. 

5 A And then along this wall -- it doesn’t quite go ali 

6 the way to the end, there’s a small table in the comer, I 

7 think it’s got a stereo on it, a small portable stereo. 

8 Q Okay. And then -- 

9 A And along this wall are bookcases. 

IO Q Bookcases there. Okay. All right. Anything else 

11 along this wall? 

I2 A Idon’tthinkso. lhrearewindowshatandbcre, 

13 thebetterportionoftbisiswindows. There’sasmallstrip 

14 that’s not, but it’s almost completely window. 

I5 Q Anything in front of the bookcase? I’m just 

16 thinking to myself then’s a table here, there’s a rocking 

,7 chair, is there anything else in then3 at all? 

18 A No. Other than golf clubs. They may have put 

19 sculptures in the windows, little pieces of sculpture like 

!O that, I think, in both these windows. 

!I Q All right What about in the dining morn? 

!2 A The&s a dining room table, about here. Them’s 

u a fireplace hcrt and a mantel. And, actually, I’m sorry, 

!4 this pantry is more flush. It doesn’t come out. It seems 

~5 like it’s flush along the wall - 

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A And that for some reason it extends out here into 

Page 124 

the hall, but it doesn’t - the hallway looks flush, so I 

don’t know how that works. 

Q Allri& 

A You know, but it’s not - not that - 

Q We can make the fitrcplaoe go out further, how about 

that? 

A Well, that’s okay. And then - they keep a small 

table there, that’s not a big deal. l’hexz’s a czcdenza hne. 

Q Two crtdczlzas on either side of the wall? Okay. 

A And then there’s one here. 

Q Okay. 

A And there’s one over here that looks more - it’s 

high and it looks more like a chest of drawers. Tall. 

Q So we’ll call it tall credenza. 

A hh-imnn 

Q Okay. We’ve got that. 

A h’h-hmm. 

Q Could you tell us where you found the books? 

A I found the one about Theodore Roosevelt in this 

bookcase. 

Q Okay. So we’ll use this black to put TR. 

A JUROR: She’s pointing to the Oval Office 

bookcase? 

Page 121 - Page 124
1390 

Multi-Page” 

Page 12! 5 

1 MR. EMMICK: She’s pointing to the Oval Offia 

z bookcase that’s to the left of the desk as one is looking 

3 toward the fireplace. 

4 THE WITNJZSS: Because you all, I think, probably 

5 see pictures of the Oval Offa and these are built-in 

6 bookcasesthere. AndthenIthink-I’mnotsureifall 

7 threeofthoseotheroneswereoverhere,butlthink~ 

8 mallin-IknowtkymreallintbeOvalOfficcand 

9 Ithinkthatallthreeofthemwereinthisbookcase. 

0 BY MR. EMMICK: 

1 Q And when you say “a three of them,” you’= 

2 talking about the President of the United States? 

3 A YeS. 

4 Q All of them. The POTUS books. 

5 A h’h-hmm. 

6 Q Okay. And that takes us right to 4:30. We’ll cmx 

7 back to this on Thursday and ask about other items. 

8 A Okay. Okay. 

9 Q I think that’s all we can do for now. 

:O A Okay. That’s fine. 

,I MR. Ehfh4lCK: Okay. Thanks. 

#2 MR. WISENBERG: May the witness be excused? 

.3 THE FOREPERSON: Yes, she may. 

‘4 MR. WISENBERG: Thank you for your patience. 

5 (The witness was excused.) 

r’ 

Page 12t 

1 (whereupon, at 4:3Q p.m., the taking of testimony 

2 in the presence of a full quorum of the Grand Jury was 

3 concluded.) 

4 ***** 

5 

March 31,1998 

i 

Page 125 -Page 126 
1391 

Nancy Hernreich, 6/l 6198 

Grand Jury 

Page 1 to Page 111 

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 
1392 

Nancy Hemreich, 6/16/98 XMAX(111) 

:31 Grand Jury Xoom No. 3 

.:3 1 United %ares Dlsfrlct Court 

: . ; 

.-A! for the 2str1ct of Columbia 

.._li 

.--_ 3rd i Ccnsr:rutlon, N.W. 

..7' .--, wasrllna:c:, ;.c. 2COOi 

:1;: Tuescaj;, ;;r.e 16, 1958 

::51 The testxnony of NANCY HERNREICH uas taken ;r, the 

::6]pre+e_ce of a iii11 quor&n of Grand Jury 9'-2, impaneled on 

::'!Septe?bber 19, :9g7, cornencrnq at 9:5O a.~., before: 

::31 SOLOMON WISENSE?\G 

.._, 

.-J1 Depuiy Inoependent Counsel 

:;;I MICHAEL EMt4ICK 

.:3j 

:I41 

:I51 

Associate Independent Counse; 

Offlce of Indeoendent Counsel 

1001 Pennsylvak Avenue, Northwest 

Suite 490 North 

Washlnqton, 3.C. 20004 

Page 4 

: : ,Do you have a yoga class or have you taken yoga classes? 

_ 

_- A Yes. I do take yoga. 

‘:’ 

.-. Q Okay. And when ts that? 

:;‘ A I usually take it on Tuesday nights. 

.-. Q What bmes? 

‘;‘ A 7130. 

.-. 

isi 

Q 

A 

: 3: I took a yoga class was probably 0 years ago or a little 

: s 1 bit longer, maybe 25 years ago. but since I’ve been in 

1: 1 Washington, I have taken 

:::remember. ‘94, ‘95, proba 

12: one term and then I didn’t 

. then I’d pick it back up again, but consistently I think 

I;ifor about two years now. 

16: Q The class starts at 7:30, when do you have to leave 

1-2 the White House in order to o there? 

.q. A I leave the W I? rte House between 7:00 and 7:15 

1 ii usually. Sometimes earlier. Sometimes I run to yoga dass 

:::and so when I run to yoga daSS. I would leave earlier. 6:30 

.Ii]OrSO. . 

.__, Q And when the yoga class is over do you return to 

1:: .- i the White House or do you go home from there’! 

L-41 A I usually go home. Actually, we usually go to 

;zsldinner because I have fnends who take yoga with me and then 

Page 2 

” I PROCEEDINGS 

ilWhereupon, 

:3: NANCY HERNREICH 

;4 lwas called as a witness and, after having been duly sworn by 

: 5; the Deputy Foreperson of the Grand Jury, was examined and 

: 6 1 testified as follows: 

:‘! EXAMINATION 

:?I BY MR. EMMICK: 

:5: Q 

: : : 1 before. 

Ms. Hemreich, my name is Mike Emmick. We’ve met 

.-;I A Yes. 

“‘1 .-- Q This is, we hope and expect, your last grand jury 

: 13 j appearance. 

“4’ .- > A I hope so. 

.. i. 

.--, Q What.1 would like to do first is to remind you of 

: 16 1 some of th; ad;;;rtrons that we routrnely start off wrth. 

-._, 

- 

::?I Q FirsY you have the right to have an attorney 

-131 outside the grand jury. Do you have an attorney? .^_) 

.-_, A Yes, I do. 

._. 1 --1 Q Who is that? .^_. .--1 A Gerry Treanor. 

.I?; Q Is he outside? .^ .: .-*, A Yes, he is. 

Z5! Q Okay. You also have a right under the Fifth 

Page 5 

: : 1 Igo home after dinner. 

--i ,-, Q 

:3lregular? 

And is your attendance at these yoga dasses pretty 

;:! A Yes, it is. 

:j’ Q Do you have any comparable regulari 

fy 

scheduled 

:c;activities that take you away from the White House, or 

: - : example, wrth any y ula?? 

:s; A Well, don t hink so, but something that’s 

: 3! regularly scheduled at a specific time? 

II:: - - Q Yes. 

“11 A I can’t think of anything, but if you’ve got 

i 12 I something2 rely;i,tne of - 

._ 

.-3; 

::;: A But not that I can recall. 

,- =. .-aI, MR. EMMICK: Okay. Any questions from the grand 

Y 16 I ~ut-y about that subiect area? 

::;I Q Seeing none., my next question is there has been 

:: 2: some reference to your havrng a meeting with Monica Lewinsky 

:::! rmmedlately after her - either having a meeting or planning 

: 1: I to have a meeting with Monica Lewrnsk after she was 

: z 3 1 terminated from her job at Le 

I: 4 1 to ask you to think back on w i? 

islatiie A );, airs, so I’m 

ether you had such a 

goin 

mee P rng or 

: r 5: whether you planned to have such a meeting or discussed 

: 1 :Amendment to refuse to answer any 

Page 3 

9, 

uestions that may tend to 

: 2 1 mcriminateAyouYe~ you understand t at nght? 

-31 .-2 

:4: -Q 

--. 

You have an obligation. That obligation is to tell 

; 5 1 the truth and that obligation is imposed because of the fact 

: 6 1 that you hr t;ken an oath. Do you understand that? 

__ 

:3! Q If you were to sa 

i 3;false. that’s materially false, tha fy 

something that you know to be 

could constitute perjury 

: : :: and that’s a crime that tames a five-year maximum penalty. 

: : : : Do you unfrstaat. that? ‘.?‘i 

.--. 

::3! Q All right. What I intend to do then is to start 

: 1.1 I off with some quesbons, but let me start preliminarily by 

::slsaying or by asking, rather, whether in the time between this 

; : 6 1 appearance and your last ap earance ou have thou ht of 

: :-:anything that has made you P. hrnk, “We r I. gosh, I nee 8 to 

: : 3 1 clanfy or expand upon m past tesbmony ? 

::31 A I don’t thin r, so. I haven’t, you know, come across 

::I] anything that’s caused me to think of that coming In today. 

:z::No. 

--’ .--I Q 

::3jthen? 

All right. Fair enough. Why don’t we get started, 

:14] A Oka 

:Zjl Q My &st question has to do with yoga classes. 

: :: having such a meeting at all. 

Page 6 

.‘: A I have no recollectiin of that whatsoever. You 

‘; j know, if somebody told me I did it. I wouldn’t den 

i; 1 if you could show me somethin r? 

it or 

3. 

that indicated I rd. but I 

:s:certainly have no recollection o rt and I have no 

: 6 lrecollection of 

::jwas terminate s 

lanning one or having one with her after she 

[jl. Q 

;3!rs it not? 

Is it the kind of thing that you would remember or 

1-31 A Not necessarily. Honestly. 

[11] Q Would it be unusual for someone in a position like 

::z ~Leqislative Affairs to meet with you and have some drscussion 

.--_ r - 2 1 relsting to her termination? - 

:I4j A Well, I think the L islative Affairs part of that 

[ :jjquestion is not - ti doesn’t relate ? o that. It’s not 

: : 6 j unusual for a young person in the White House to come to me 

: ~7 I and talk to me about their position in the White House and, 

: : ?! you know, their future. That sort of thing. 

&- 1 Q Why is that? 

;z:i A I don’t know. Maybe it’s - I don’t know. Maybe 

:I:: I’m motherly. I don’t know why. But I do seem to et a fair 

:tz : share of young people who come and talk to me a % out that. 

: ~3 1 Maybe its my 

;:J 1 tenure at the \R 

roxlmrty to the President, maybe it’s my 

hite House. I’ve been there from the 

::slbeginning. 

OlCStarr Page 1 fo Page 6 
1393 

SSA Nancy Hemreich, 6/16/98 XMAX(ZR) 

Page 7 

And hopefully. it’s - you know, partially just 

li; because I have an open door and I’m nice to people, 

131 hopefully, and they feel comfortable coming to me. 

Q So it wouldn’t be unusual if It had happened, but 

iz!you ‘ust don’t have any recollection of it either occumng 

16;or planninifor it to occur. 

i:i 

Q 

That’s right. 

Okay. I want to ask about a specific occasion and 

it 1 that is did there come a time when you were In your office 

1 loland Monica Lewinsk 

1111 Oval Office or towar J 

and a thirty&h white female came to the 

the Oval office, they were stopped by a 

[ 12 1 Secret Service agent by the name of Byrne - do you know a 

I 13 ISecret Service actent bv the name of &me? 1.. I 

Cl41 A Y&s, I do. 

0 You stepped out of your office to say to that 

i:ziSecret Service agent somethin 

- 

117 JVOU had a discussion further WI 9 

like, “It’s okay,” and then 

h Monica and possibly with 

i ;3 ifhe woman she was with. 

[I91 A You’re ,asking me if I recall that? 

[IO1 

[.?I! 

Q Yes. Imtrytn~~ 

A I have no reco cbon of that whatsoever. 

Q Okay. Let me just give you a couple of other bits 

1Z-3 jof informa? tG;Ee if it will jog your memory at all. 

[241 

[251 Q Andythen Monica left your office, said something 

Page 8 

[llabout - 

i:! 

[31 

Aa t;;;d you go back a little bit? 

A Because you said -were they approaching the 

iii outside or were they coming in to - I don’t - 

L61 Q I don’t have enou h detail to know. 

(71 

c8i 

A Okay. All npht. ,&a~. ~ 

Q My mforma ion IS that the were somewhere in the 

~g~vcrnrty, they were stopped briefly by the ecret Service 

Ii81 A No. I have no recollection of a discussion of 

ilgjthat. I mean - and 

~30 I information that mrg .K 

ou may be able to give me more 

t refresh my memory, but did it happen 

! :: i before or after she was - you don1 know that? 

i2lI 0 Don’t know. 

'131 A And we don’t know how far - if she came into -to 

is4 Ilike to the inner office? Or if she was standing outside 

:251 looking into the - sometimes peopb - the guard, Gary 

Page 9 

i: 1 want to show somebody the 

[hItimes when pu would - I would go out or the would ask me 

[ 7 1 or the Secre Servrce would ask me is it okay ! or them to 

18 1 see - first to open the door and let them see the inside of 

rsrlthe Oval. 

And so - and that might be something like that 

ii; 1 But that’s not particulartv unusual. either. That would 

i 12 j happen several times a day. 

ii: 1 

Q Sounds like you’re ex loring different 

ossibilities about what would make P hat more likely to 

1151 F: 

[I61 

appen or?iK! 

K 

gmhappen. 

i171 Q And that would have to do with, I guess, whether 

: 18 ithe President was around? 

[15: A Ri ht. 

Q 

1:; i Office area as o posed to just passing by. 

ðer she was walking quite closely to the Oval 

[22; A 4s. I guess. I don’t know. Gary may have come 

[23:in there and asked me - you know, sometimes my door is shut 

~~4land he may have, you know, not wanted anybody to come into my 

[ ~5 1 office or something and, you know, they may have stepped in, 

Page 10 

[I 1 but that wouldn’t necessarily have been usual. I’m just 

[: 1 trying to recall it and so - 

13: Q Riaht. Let me throw out another oosslbilitv. If 

i 4 j in your role as gafekeeper. if 

[51were walkin 

+I 

around the Ova 7 

ou were to think tnat someone 

[ 6) to speak wrt 

Office too much and you wanted 

them, is this a possible way that you would 

[ 7 1 speak to them? 

Because it seems like 

Okay. Well, I’m just asking really whether if you 

[I 61 were to talk to someone to try to discourage them from 

[ 17 I around the Oval office so much, the scenario that I just 

coming 

t~s]described to you is one way that it might happen. 

That is that they would be walking In the Oval 

~:~~Qffice, you would become aware that the were around, you 

tzl ]wouM call them into your office, you wou ry ddacuss with 

tzzlthem the fact that, you know, they shouldn’t be around here 

tz3lunless they have business and then they woukl leave sayrng 

[24]"l'm Sony. 

1251 A Well, I’m trying to think if I’ve done something 

Page 11 

111 like that. You know, we had - people bring guests in and 

[ 2 I we’ve gone through various sort of structures of rules 

[ 3 1 regard&n 

[ 4 1 into the 8 

that door open or shut and whether people can see 

val Office or not and my personal view of it 

(51 

3. 

enerally was that when you have a guest and if the 

ty 

‘re not 

~61 rsturbrng anybody down the hall or in the Roosevel Room or 

[ 7 1 any other meeting is going on right around there that it 

[a 1 seems perfectly appropriate to be able to open the door and 

tsllet them in. 

I don’t know kind of exactly where I’m 

I:Fi this other than just trying to figure out under wha 9 

oing with 

(12 1 circumstances. I’m tryin 

~131 have gone out and said, %V 

to recall if I’ve ever - I may 

ell, you all. there are meetin 

9 

s 

~14 lgoin 

[15]nght 9, 

on here, we can’t really - you can’t be hanging ou 

ere, right now, there are people.” 

So sometimes if the Presidents between the 

j:76;Roosevelt Room and the Oval Office, I discourage people from 

(IS! being in the halhva 

[ lgldown the hall and ty 

then. And if there were thin s going on 

know they’ve ot a uest an they’re 

[20 1 not - that’s basically - they shou ? d not %e takinitherr 

[zl!guest down the hall, then I would discourage them. 

But other than those circumstances I can’t think 

I:iiof a time, although I certainly may have done k where I 

[24 ] have, you know, discoura 

‘1 

ed 

tz5lYou know, hopefully I wou d 

someone or totd them to go away. 

be nicer than that. 

Page 12 

ii 1 

I mean I really feel like that a lot of this is 

1! 

ou should be nice and 

a. 

racious to people and not rude and 

131 m not, I try to do all oft is in a nrce enough wa 

~4 1 I understand their oint of view, but not disrupt t 

[ 5: workings of the W&e House. 

K 

so that 

e 

Q The next subject area I’d like to get into is gifts 

17”; and gift procedures. If someone were to give you a 

[s 1 of thmgs some of which were for you and some of w 1. 

ackage 

rch were 

[ 91 for the President,, what procedures would you employ to try to 

tlolaccount for the rfts? 

A dell I usually give it to someone else and ask 

i :i; them to do a gift form. 

Q 

That s primarily what I would do. 

j::jgift form? 

Okay. Can you expand on that? Have them do a 

A Well, they would fill out a form which would be 

I:zisent to the gift unit so that the person can be thanked for 

[l7]it. I don’t do that in 100 percent of the cases, but 

~lelgenerally that’s what I would do. 

Q Would 

~:o’~woukl you have the gr .ff 

ou show the President the gift first or 

form filled out first? 

1211 A Well, R’s not 100 percent. I wouldn’t do it every 

[zz Itime. I think all of it is the circumstances. But normally 

tr3jwhen things come to me,, they come to my assistant first. My 

t241assistant would automatically do all of that. And we’ve 

[25]changed procedures. 

Page 7 to Page 12 OlCStarr 
1394 

asA Nancy Hemreich, 6116198 XMAXW3) 

Page 13 Page 16 

For a while, they would bring it up to me and at 

i<:some p01r.t I said just do the gift form before you ever bring 

; ;! it to me and then show it to me first and then I’ll go and 

:; ; give It to the Presrdent or whatever. But sometimes in 

:5!certain urc;;mstances, it might come m and he might see it 

j E Jfirst before we’ve had a chance to do a gi! form on it, so 

I 1 J in those cases then he would see It sometimes first. 

,::I Q The gift form should be filled out regardless of 

; 3lwhether the President sees it first or whether the grft form 

[ i: 1 is filled out first, I take it? 

A Well, we try to do that. I don’t think we do it in 

i ii i 100 percent of our cases, but we try to fill out a gift form 

::3:0n g&s. 

ii$form? 

Q What kinds of cases would you not fill out a gift 

;16j A Well, I think if we just - in my particular case, 

: 17 1 I can’t speak for others, but in my case, d its something 

! 13 1 he saw and I was really bus 

; 141 a chance to do it and I just fy orgot about it and just didn’t 

and he ptcked it up before I got 

:23lfill it out. You know. So that’s a possibility. 

:?I! .--1 Q Well. foraetfulness. I think. is a common thina. 

I22’ A Yes.’ - 

l23j Q But that wouldn’t be a matter of policy or 

: 2 4 1 practice, I take it. 

[251 A Well, it’s not what - I. again, my particular 

Page 14 

i 11 items usually come to m assistant and at some point ou 

i z! know, our policy was jus Y fill out the gift form in the ba cl! 

c 3 ! they’re down the hall, away from me, before ou bring it to 

L J 1 me. It just makes it easier. And so the gifts r hat come to 

(5 1 the President throu h me, then that’s what I do. 

15: Q Wou 9 d that same procedure apply to gifts that come 

; 7 1 to the President through Betty Currie? 

A You know, I thmk you’d have to ask Betty how she 

I Ei handles those because she doesn’t necessarily have an 

; 13 1 assistant who’s oin to sit there and do all that and she is 

i : 11 right outside of t 88 e val Office, closer to the President 

c 12 1 than I am. And so she may set something aside that comes to 

c 13 1 her and, you know, he may pick R up before she has a chance 

: i 4 1 to fill out a form easier. 

:15: Q Well, do you mean to sa that there are different 

: i 6 1 

: 17 ! E 

rocedures that ap 

r: 

r 

ebecca Cameron. 

ly to Betty than wou d apply to you or to 

!:?I A Well, I think everybody handles it in their 

: : 4 1 own wa I think the eneral procedure rs,that we try 

:I?:,fillou~agiftfo~. ?thinkyoucantsayrnall, 

;: 11 cases that ou do that because just different circumstances 

* -7 7 exist and I hrnk we all do our best to fill them out or 

f!; i to do that. but we don’t do it in 100 percent of the cases. 

:24jAnd there are just, you know, times that it falls through 

12 5 1 the cracks. 

Page 15 

Q All right. 

A So generally, I can only really speak for myself 

OlCStarl 

[I; and a gift form, we fill out a gift form on things that come 

[2lto me. Another instance. for instance, where I may not fill 

[3!it out but I would send rt to Personal Correspondence and 

[ 4 1 have them do a thank you and then I would just make a copy of 

[ 5 1 the letter for the gift unrt and maybe a gift form wouldn’t 

[ 6 1 be filled out then. 

Y 

way that Monica 

et’s say, 

I don’t think I was aware of that. 

II11 Cl 

A 

Okay. You sound like you have some hesitatron 

Well there was some awareness. Somehow, I have a 

iiiiawareness of a tie ’ ossibly being given to him 

P 

but 

not 100 percent certain of tha -r 

ou 

[14!know, I - I don’t - m 

rls!But - and then - but that’s the only gift that I maybe am 

[~s~partially aware of, that I remember. 

Q The gift forms that Betty Currie would fill out. 

Iii iwouid they be forms that would be sent direct1 

Y 

to - I guess 

tls]it would be the gift unit or would she give that orm to you 

[zo~or to Ms. Cameron? 

1211 A I think she would handle it directly, but I don’t 

122 Iknow. Again, I think that’s a little - it’s a little unfair 

[z3]to ask me what she does with them or how she handles them 

r241because I really don’t pay that much attention to how she 

rzslhandles them. 

Page 17 

Q Well, then I can just ask it in terms of what the 

I:; procedure is. What is the procedure? 

(31 A 

[4lbe - 

My procedure, what Rebecca and I would do, would 

usually we would attach a copy to the gift and send one 

[alto the gift unit. I think that’s - and actually, since 

[ 61 Rebecca does all that I don’t pay a whole lot of attention 

:7 1 to ti, even what I do. Rut that’s - sometimes the whole 

[E] acket comes in t ether to me with the gift form attached to 

[ 91 P. he gtft and hopefu 99 y they’ve made a copy of it and sent it 

[molto the gift unit. 

1111 Q When I asked you what the procedure was, our 

[:zlanswer was here’s what I do and what Rebecca does. Tha r 

[ 13 1 again implies to me the suggestion that there are inde ndent 

rl4lprocedures. there are different procedures that Betty r, ume, 

[lslwho works for 

[ 161 unaware. Tha ty 

ou, may be using procedures of which you’re 

sounds odd to me. 

A No. I don’t - that’s not what I’m necessarily 

[:i Itrying to say. I think what I’m tryin to sa is that I 

rlglthink the onlv oerson I can speak or - I 

i?o j over her andwatch her and ia 

P Jo. on t srt and look 

this is what 

In fact, as I’m sitting K ere talking a ‘b 

ou’re doing. 

out It I 

I:iidon’t even know that I know what Rebecca does with the things 

[23 1 that come throu h me. 

[ 24 1 thought, well,, I 8 

I started talking about it and I 

on’t know that they make a cop and send it 

[25]to the grft unit. And she may bring in the whole Y. hrng and 

Page 18 

[I 1 sometimes it’s usually interns who will do 

~2 lwhole thing up to me and I may stick the 

[ 3 1 for the President and we may not pull the 

I41 I don’t know. That s the bottom 

[slto be out here on - ou know, talking about it when I really 

[slam not certain abourit. 

Q Right. In my mind ou’re talking about two 

Iiiconcepts and I want to make sure’ & at I’m not confusing them. 

[sIThe concept I’m trying to get to is what should happen, what 

1 Io 1 is the procedure that IS supposed to be followed. 

And what you seem to be responding to more is what 

/::lactually hap ens and that is somethin 

t13lsitting at Bet) 

that since you’re not 

Curries desk ou don t ave any direct 

1 I4 1 know edge o , but you would 

yh ’ ?I 

r~s~procedure 

ave direct knowledge of what the 

is and what should happen. 

A Yes. Well, I 

I::i I’m not even certain that we 4 

uess the other thing I’m saying is 

allow precisely the procedure, 

[18lwhich is that that form makes it to the gift unit, as it 

[lglshould. 

Q Right. But there is a procedure, whether you 

I:y]adhere to it each and every time is a different question, but 

[zrlthere is a procedure. 

A The 

/::;unit is notified of ai R 

rocedure ultimate1 would be that the gift 

s received bv the J resident so thev 

i25jcan keep a record of them. 

Page 13 to Page 18 
1395 

BSA Nancv Hemreich. 6/16/98 IMAWUI, 

Page 19 

Q All right. And would the 

:c review whatever gift forms Betty Cume c: 

rocedure be for you to 

ad filled out to 

: 3 ‘send to the gift unit or at least to have a copy or the 

::. 

..onginal oftAhat Eoy passed through you? 

.3 

it: MR. EMMICK: All right. Good. 

,-- Does anyone have any questrons about the gift forms 

j 5 j or the gift procedures? 

._. 

.g. 

;I:: ~+r;;p$&K: 

. . . . ,.A_ 0 All right. Seeing no questions, you had mentioned 

: :: : earlier, if I recall, that with respect to correspondence 

! 1: -that comes to you, sometimes 

f 

ou would gather that 

‘. ; : correspondence and wait for a ime and then either send it to 

i i 3 : Personal Correspondence or send it to the Office of Records, 

! : 6; but there was a somewhat informal arrangement for compiling 

; 17: correspondence before dealing with it formally. 

[ : 2 : remember that? 

Do you 

Ii9‘ A No. I don’t. Not that. Talk some more. Remind 

[ 2 c i me what I - that is not - I wouldn’t necessarily say 

12:: that’s what I usually do, that I gather it all and then send 

[X:it off? 

0 I thought I had recalled that on occasion you 

/zijgave correspondence to - you held correspondence either 

~25; rn your office or Rebecca Cameron’s office prior to handling 

Page 20 

c 1: it formally. That is, rather than sending each and every 

::: letter off to Personal Correspondence or the Office of 

13 1 Records Management, you might wart until you had 10 or 15 or 

:4:&J. 

:j: 

:6: 

.?. 

19 i it on the fr”,“t e:rJJzending it off to be responded to. 

(9: 

110‘ 

; W$ are you talking about filing it? 

A Oh. Okay. I didn’t know if - because I deal with 

A’ 

i ; I i well. Yes. 

A;dry.have it - and I don’t have all of it as 

I think it’s more than 15 or 20. It may be held 

i 12: for months. six months or a year, before anybody gets around 

r. _ - : gather several of the gifts before any gift forms are 

!:s:out? 

!:j: A I don’t know. You know, let me back up. I think 

;: :. there’s an important point here that is sort of missing. 

._. __. Q All ri ht. .^^. A And t 3, at is early on I gave Betty the 

i?; j responsibility of handling gifts and so that basrcally the 

[34’only gifts that I handle are the ones that come directly to 

:f5:me. 

Page 22 

[ 11 ifts and then somettmes they’d just bypass me and give them 

ri 1 %. lrectlv to Betv. And sometimes thev would - 

So sometimes I would see them. Then I asked 

tls]She did the gifts. 

Q 

I:Z~;assistant? 

And, again, the they would be your intern or your 

i21i A That’s correct. 

;;z;to Beg, _P 

rf she picked it up at one of the 

All right. Now, rf somethi? 

at& for 

if a package came 

[24 lexamp e. rf rt had been delivered to her, I was boxed up, it 

tz51came to her before anybody had done anything with it, then I 

Page 23 

t 11 assume that would also mean that a 

.~, 8 

ift form had not been 

rz 1 filled out. How should she handle it t en? 

I31 A Well I don’t know how she should handle it. 

[ 4 1 Again, I think what i said earlier was that eventual1 h;ttet 

tsjthere should bs some notification of the gift unit. Iy 

[ 61 IS 

[ 7 1 Bu 9 

enerally some notification of the gift unit of gifts. 

, you know, that doesn’t happen in 100 percent of the 

[ 8 1 cases. 

[91 Q All right. Are you aware of the President keeping, 

[lojgathering together gifts either in the Oval Oftice or in the 

[I 1 I study, keeping them in a bag, keeping them in a cluster so 

[ 12 1 that at some pornt he would either do something with them or 

[ 13 1 say, “Betty, tiy don’t we fill out grft forms for tbs.” 

[ 14 1 anything like that? 

(191 A 

Q 

I’m not aware of anything like that. 

Woukl there be anything unusual about that, if it 

I:;ihad happened? 

[I81 A For him to - unusual about what? 

Q 

i:iihandled it th 

For him to have gotten a couple of ifts, not have 

rzllfinally sa 1 ing ~~‘~~,~:.g~~~~~t~~~~~~hy to 

t221don’t we ake care o the paperwork on it?” 

A Well, I’m not certain what you’re asking. If you 

i :: jcould be a littk more specific about what you’re asking me 

tzslthere. What portion of that are you asking me? Because 

Page 21 

:1. She handles mostly the intake of 

)s : once - like for instance a ifl with a g 

&e it to her. But 3, 

ii2 

ifts and I think 

form comes to 

: 3: me, I will 

:; : the Oval 8ff 

er desk is right outside of 

ice so the President walks in and out by her desk 

i:sjhandle? * - 

Page 24 

I 1 lyou’ve got about three parts of that. 

I21 Q Let me describe something and then I’ll ask you the 

[ 3 1 question would that be unusual. 

t41 A Oka Good. 

[51 0 AndYthat will have fewer parts. 

[Cl A All “gt$ 

0 lf Be 

Iiishe were to give the 

were to receive 

resident these 91 

,R 

ifts for the President, 

191 President were at some pcint,Jo 

s, and if the 

sa 

I 10 1 the papew;rk ;rttrese grfts, 

Betty, lets fill out 

wou lye d that be unusual? 

[Ill 

[l?l 0 

A 

In what respects? 

I :: i “Let’s fill out the 

Well, I’m not sure the President would say to her 

1151 Q Ai 

aperwork on this.” 

ht. What would he do instead? 

[I61 A I don “9 know. I don’t know that he would ever 

[ 17 1 think that we have to fill out the paperwork on a set of 

rlsigilts. 

Cl91 Q You think he might not even know that there’s 

r2olpaperwork to be filled out? 

I211 A 

Q 

Well, I think he - 

Or he just wouldn’t bother with that aspect of it. 

I::; he would just assume Bett 

J 

would take care of it? 

t241 A I think so. ut you’re askin me to - you know, 

t291fo judge or to assume something that’s in #. IS head, you know, 

Page 19 to Page 24 OlCStarr 
SSA 

1396 

Nancv Hemreich, 6/16/96 

Page 25 

[ 11 about why he would have done it. 

I-i 

,-. I don’t know. but I don’t think - I don’t recall 

Page 26 

[El Q 

A 

What’s the Oval Qffice procedure? 

[91 My procedure for handlrng it, if someone sends me 

[ lolone. I will open mine, I will open his usually, and I will 

[ I I 1 put his in a folder and put it in his box for hrm to pick u 

! I 2 1 And that’s not 100 percent. Sometimes I’d send it off P. or an 

B 

ive it directly to him. 

asked the question what’s the 

started to say I don’t know what 

en you said what your procedure 

[17]IS. 

[I91 A Mm-hmm. 

1191 Q 

:I?01 A 

Are there two different procedures in play here? 

;zl]might handle 

Well, I think in a way there are. I think Betty 

- I ask that Be 

!z?lse it - I notice that she does tt7 

give them to me., but she may 

his, she doesn’t grve it to 

:: 3 I me 100 percent of the time and she makes deusions herself on 

1~4lhow to handle it. 

!35i Q How would you expect her to handle it? 

Page 27 

[Ii A I ask her to give it to me first, but to this day, 

[zlshe doesn’t. So she makes decisions. And I think somehmes 

[ 3 I she sets it behind her, the President picks up things. And 

[ 4 I if I’m not there and she thinks it’s something he needs to 

r 3 I see, she’ll hand it to him directly. 

[Cl Q 

[71 A 

Why IS it that you want to see these items? 

Wel. because I feel like I need to screen, you 

e two reasons that I ask to see 

[15lthem first. 

Q Sounds to me like there are different parts of what 

j::jshe may do or does do or you expect her to do. 

ilsisure I understand what the Darts would be. 

Let me make 

il9! Would you ex ct her to o en the - let’s call it 

!zolthe correspondence tha Fe s addresse s to the President before 

[ 2 11 giving it to the President? 

A 

l%lcomfortable doing that than she IS and I don’t notice that 

She doesn’t always do that. I am much more 

~241she always opens the correspondence to him. 

1251 Q Do you think she should? 

XYAX(S15) 

Page 28 

A Not necessarilv. 

._- Q 

: i : Presrdent? 

Is it the procedure to ccen the letters to the 

:;- A It is the procedure for t-re to open the letters to 

: 5’ the President. And not 100 percent cf the cases would I 

: E. them. If someone asked me not to. tney tell me - a staff 

open 

1-1 member says ‘This is a personal note :o the President. I 

: z :would like for him to see it and prefer f no one else reads 

: 3: it.’ then I would give it to him directly. I try to respect 

::;:thelr pnvac 

_--. CK And what paperwork would be filled out In 

: 1:: connection with that correspondence !nat has been given to 

: 13 : the President? 

~. . . .-9. A No pa erwork would be filled out. ._i 

..-. _--. Q All rig R t. .-t. A 

; :-:donr think 

I’m just - I’ve got to make sure of that, but I 

there’s any paperwork that we till out on 

:: 5 1 correspondence. 

::9: Q How would a thank you note or a response be put 

:33:together under those circumstances. if one were to be put 

:z::tooethet? :_,: - 

.--~ A 

know, 

Well, if it’s appropriate to do a note back, 

I: 3 : you I would either send it to Personal Correspondence 

: 24 j or to General Correspondence or I would send it to the 

~351 staff secretary. I’d send it to a specific person in the 

Page 29 

: I 1 correspondence de 

iz: the President woul 8 

artment. It’s just various. Sometimes 

hand write a note back. 

131 Q Is it fair to say that - it sounds like what 

:4 I ou're saying is that you would leave a note like that with 

! 5 : r he President and if some particular response were required, 

: E 1 he would let you know. 

A 

ii i about? One that IS in an ‘envelope that I don’t open? 

Yes. Well what kind of note are you talking 

!j:. Q Let’s take one and then we’ll take the other. One 

: ~3 ! IS you open it, you look at it and you ive it to the 

: :::President. What should be done at t&t point? Is there a? 

: 1:; record kept of that piece of correspondence? Do you put 

: : 3: on a list of things that have been shown to the President, 

: ; 4 J letters that have been received by the President? 

-15: A No. 

ilif Q 

; : 7: the President? 

What if you haven’t opened it and you give it to 

Page 30 

:I 1 that the correspondence that went to the President would 

:; :ger+rally be made a 

: 3! call rt that, and I’m a 

art of the public record, if you might 

rised to hear that 

14 :correspondence that you or that is sent to Betty 

: 5 j that’s ultimately forwarded to the President isn’t always 

! 5 j logged in, if you will. 

‘7: Is my 

1s jstraighten me ou 9 here. 

eneral impression wrong or is this - try to 

:91 A Well, your general impression is wrong. The rules 

: : 3 I regarding that are what is personal should be and can be 

[ 11: kept personal. It does not have to go mto the ublic record 

::3 :and should not go into the public record. Mos P archrvrsts ” 

I 13 lencourage you not to do that. And what’s personal can be 

: 14 ! kept personal. What’s 

; g; records an; wh;fostr 

presrdentral then goes to the public 

rsonal doesn’t o to public records. 

ere would be no w- rng unusual about him not 

: 17: arranging for there to be a filing of a personal note that he 

; 1 a: has received. 

:;4: A Not unusual. No. I wouldn’t think much about it 

: 23 1 if he didn’t ask that 1 be filed in one way or another. ,?. 1 

:--_ Q Now, if you haven’t opened the envelope, how do you 

:I? : know whether this IS presidential or personal? Would you 

: 11 j leave it to him to decide that? 

124: A Yes. I mean, if someone asked me, tells me it’s 

: 2 5: personal and they say “I would prefer that no one read it, 

OlCStarr Page 25 to Page 30 
BSA XMAXWS 

1397 

Nancy Hemreich, 6/16/98 

Page 31 

: : ‘its really personal.’ then you have to respect that and 

: I: trust that.. 

.- Peo le haven’t - I haven’t noticed that an 

: ; : has done anyt R$ body in like that that’s - you know, its - r here 

: 2: might be an tsola ed case here or there, but - 

‘;‘ -. MR. EMMICK: All right. 

.-. THE FOREPERSON: 

is ;grand jury to take a break. 

Mr. Emmick. it’s time for the 

‘3’ MR. EMMICK: All riqht. Break time it is. Ten 

: : : 1 minutes? 

. , 

.--_ THE FOREPERSON: Ten minutes. 

.._. 

.--> MR. EMMICK: All ri 

I. 2. 

_--_ rtness excused. 

rv 

WI 

ht. Thank you. 

:1;: HE FOREPERSON: 

ness recalled.) 

::s;oath. 

Ms. Hernreich, you’re still under 

. . L. I-5, Mr. Emmick. we have a auorum and there are no 

: I-: unauthorized peo ie in the rand .u’ 

:13; MR. EhPNIICK: 

115. 

% d ? room’ 

BY MR. EMMICK: 

oun s Ike we can go forward, then. 

;23j Q Let’s follow u on some of the areas we had touched 

i2 1: on before. Are you aware o P 

[z~gifts to Betty Cume? 

whether Monica was giving any 

(231 A No, I wasn’t aware of that. 

:24; Q All 

:25, A Not z? 

ht. Did she ever give any gifts to you? 

at I recall. 

Page 32 

. . . Q Do you know whether she ever sent any notes or 

tr i letters or corres ‘7: ndence to Betty Currie? 

.-. A & that I recall. 

;4: Q Did she ever send any to you? 

.i‘ _-_ A Not that I recall. 

‘E: Q Were yqu aware that Monica was having deliveries 

j - j sent to Betty Curne dunng the penod - I guess you’d call 

: 2: it the fall of 97? 

_ A Fall of ‘97? I was unaware of an deliveries that 

I i3; Monica was having made to Betty - is that wha r 

i : : I savina? 

you’re 

_--. - Q Yes. 

Ilj: A 

:I:‘ 0 

No. I’m unaware of anything like that. 

All right. Where in the chain of command does 

: 15 j Carolyn Self fit? 

:I_;: A Carolvn Self was an intern. 

___. 

.- Q Did she reportto ou? 

. 2 : .--, A ty 

‘-3. Q 

No. she re orted o Betty directly. 

All 

if : i made to the White 3 

ht. &h respect to delivenes that are 

ouse for forwardin 

:2:: be the mechanism by which you would 3, 

to Betty, what would 

now about those or 

:21-would there be a mechanism by which you would know about 

:zz:those? 

‘-4: A There would not be a mechanism that I would know 

is 5 : about them unless I was told about them or just, you know, 

Page 33 

: : ‘was involved in it. was in the middle of it or saw it. 

._; j.._ Q If you were to hear or know that Monica Lewinsky 

: 3 J had sent six, seven, ei 

::: Currie in a couplemon 9 

ht packages for delivery to Betty 

: s-would be interested in? 

h penod. would that be something you 

_: A I would be interested in an one who send a number 

i” of packages to the President in a certain 1! rme period. I 

: t jwould be interested in the fact that peo 

:?’ Q All right. Is it the kind o 

: : ; i expect Betty to let you know about? 

P 

le sent packages. 

thong that you would 

A I would expect Betty to tell me about packages or 

! ir i letters that were being sent on a regular basis to her. Yes. 

.._. .-1, Q Did she tell you about such deliveries? 

1::: A Not that I recall. Not that I recall. 

i151 Q Okay. It sounds like 

( : E 1 about that or is it simply just a lack V 

ou’re not entirely sure 

o recollection but 

: 1-1 its a possibility? 

[:?I A Well. I think in all cases, I mean ou know, my 

1:9:memo 

.X 

is not the best in the world and especra .* r ly the older 

:::I I get It ecomes worse,.but I don’t recall it. You know, but 

[ z 1: there’s always a possrbrlrty somebody would have said 

; :z :something to me. 

t-3: I mean, that could happen in five minutes, someone 

! 1: : could tell me something and I could turn around and ask them 

!zs;the very question they just told me. Sometimes it’s just 

Page 31 to Page 36 

Page 34 

: :! having too many thin s on my mind. It’s just a bad habit of 

12: not paying enou h a 

Q #d 

t? entron. 

‘31 I 

‘4 i For examole. did 

anyone other than Betty report that to you3 

Carolvn Self or anv of the other interns or 

;5 janyone efse who had picked up any-of these deliveries. did 

:6]they say, “Gosh, Monica’s sending all these packages. What’s 

[ 7 j going on?” 

!?: A Not that I recall. 

ii 3 j your infe?est? 

1191 A 

tzojwere sent to 

Well, I think that overstates it. If the packages 

Be 

.?’ 

then that’s of no interest to me. But if 

121 Iwe’re having - rf here are a lot things that are being sent 

[22)to the President - 

1231 Q Yes. 

1241 A -then that is of some interest to me. 

[251 Q Why? 

Page 35 

A 

I: i amount of pa 

Well, because I like to know and you know, the 

rwork that he receives and to d able to 

[ 3 1 control it so t R” at he’s not overloaded with that sort of 

14 1 thin And to be able to monitor if someone’s sending a 

:s)lot o V thongs in through her then if there are issues 

[ 6 J related to that we need to be on top of, you know, then 

[~lthat. 

I89lanother cabinet member or 

!:2lmember. 

It sounds to me like this has more to do with the 

iigifact that they’re all from a particular person and what that 

r2olmight impl 

x 

Is that right? 

What you’re asking me is if I would be more 

iz: 1 concerned that a number of packages were coming to her from a 

[ 2 3 1 certain perrQOn, $‘t’the person I would be concerned about? 

:241 

:251 A More concerned about a person? Well, I think 

Page 36 

1131 may be blind sided on and if ou’re oin to send something 

t:41 to him ou should send it to im wit al 

!:slinformh!ion. 

X. .3, P the correct 

Q Would there have been any special interest in the 

fi76ifact that it was in this case Monica who would be sending a 

[I a 1 number of packages for delivery over a couple-month period? 

!lg]Ariy special concerns? 

~~~~vou know. 

A Well I don’t know that any special wncems - 

I can’t s6v that now. I mean. in retrosoect. I 

i;zjdon’t know. 

. . 

!231 Q Were you aware that Monica Lewinsk was visiting 

:24 1 President Clinton dunng 1996 and 1997 after she ha J left 

i251OlA? 

_ 

OlCStarr 
1398 

q !sA Nancy Hemreich, 6116198 XMAX(7/7) 

Page 37 

. 

: f ‘President. 

A No, I was not aware that she was visitin the 

I think that we had talked about before that 9 

: 3: knew that she had come to a radio address. Other than that. 

: 4 I don’t know that I was aware that she was visiting the 

: 5. President or that she did visit the President. I’m not sure 

: E : I’m aware of that today. 

._. Q Were you aware that she was having visits to Betty 

i 5 f with some regulari 

‘i- .-_ A No! T 

? 

was not aware that she was visiting Betty 

[:;:with some regularity. 

[::: Cl Would you expect Betty to let you know if she had 

!I:: had - let’s try to put a number on it. Let’s say, you know, 

(13 : monthly visits from Monica Lewinsky while ou were not there 

( I: : and were therefore not personally aware o fJ 

i13: A It would not be unusual for Be 

i ; -: :visits from somebody and my not be aware of ? 

to have regular 

hem. 

.._. 0 

1 I? j Lewinsky had visited with 

And would ou want Betty to let you know if Monica 

tYl 

‘5‘ A 

at regularity. 

Well, I think if Monica Lewinsk js? jfriend of Betty’s and that’s a personal visit by t is a personal 

onrca to 

12 1: Betty, then there’s no reason for her to let me know. I 

~22 lthink that’s a friendship separate and apart from our work 

[:5jand there’s no reason for her to inform me of that. 

[24! 0 And if they were more than personal visits or 

[z 5: perhaps personal visits as well, that is, if they were also 

Page 38 

; : ~visits to the President, is that something you would have 

;: :expected Bettv to let vou know about? . 

A 

I ii her to let me know if Monica Lewinsky was vtsrbng the 

-I would have liked to have - yes., 1 would expect 

:5: President on a re ular basis. 

‘i‘ i*_ Q Wz? 

I-. A Wel, r because I like to control 

[ 3 i number and amount of people he sees and to - 

: 3 I almost for the same reasons that you would do t 

[ : :: my lob and I would like to be able to - you know, if there 

[I: : are Issues that someone is talking to hrm about, then make 

[ z : sure he’s not blind sided on those. 

[I:: Q I’m not sure I followed that last one. 

: -- . ou know, because there are issues related to tha 

1;;:): resrdent would need to know about but there might be other 

[ 2~ : issues, too, that he should be hearing all sides of an issue. 

; 2 5 : And so that’s what I mean by that. 

,. 

Page 39 

So that if there are - because of issues and who 

i! j it is that’s visitin him that - 

Q Gould there be any special issues raised by the 

i 3 i frequency of visits from Monica? 

.-. 

[i: 

t Fe;e President? 

r-. A Special issues? I don’t know that I would have any 

i ! ispecial issues unless it was something related to the 

: 2: Department of Defense, you know, and I probably would have 

I :: : asked that question. 

Q All right. Were ou aware that Monica was 

I ~~‘frequently callin 

[I?; A %t that I reca I. 

Betty durin $ !997? 

11’: 3 Q 

::5: A 

Did Betty mention to you any calls from Monica? 

Well,, I don’t remember, but she might have. I 

[ :E: can’t - you know, I just don’t recall. 

[IT: 0 Did she ever complain to you about the number of 

I: 5 : calls she had received from Monrca? 

[ls: A I don’t recall that she did. 

12:: Q You supervise Betty. 

[?I: A Yes. 

!:I: Q Are 

~23: calls that might be l? 

ou someone who would be concerned about any 

rsruptrve of Betty, either because of 

~2;: their frequency or their manner? 

[25: A Well, I might be concerned, but Betty and I have 

BIC-StaW Page 37 to Page 42 

Page 40 

[ 1 :different personaIdes and one of the things that I admrre 

:: : about her IS the fat that she is so nice and gracrous to 

~3:everyone. And shes been in here. you mrght ask her about 

:;~some of the eople she gets on the phone and she’s always so 

[ 51 gracrous an cf- nrce to them. 

:E; And real!y literally, mentally ill people who 

r-jwill call her on a regular basis and say that they are 

! 9 1 the ambassador to tiatever, or they were promrsed to be 

: 3: ambassador to somebody and she’s 

9 

racious and kind and nice 

11~; to them day after day after day. And not sure I would be 

r::jthat gracious and kmd and nice to these people. 

And she. you know - she always treats them with a 

Iii i lot of respect and you have to admire somebody who is that 

: I:: kind and good to people. 

[:5: Q 

[ 16 j disruptive, 

We do have to admire that, but it is also sometimes 

if you’re so gracious and taking so long with so 

[ 17; many calls that it d6rupts your work. 

I::;with Betty and Monica at all? 

Did you have the impression that that was happening 

[?Cj A 

rc’llabout it. 

No. I did not have that impression. I didn’t know 

. 

Cl 

/g:iphone, yelling at someone? 

Have you ever heard Betty speaking loudly on the 

A 

ii:;of my head, I donY recall her yelling at anybody. 

Well. certainly not that I recall. Not off the top 

Page 41 

Q 

Ii I made to the President through Betty? 

Were you aware of any calls that Monica Lewinsky 

131 A Not that I recall. 

I41 Q Let’s talk a little bit about your work hours. 

[5! A Okay. 

;;i 

Q What are 

r 

our work hours? 

~8 iof ei 

A 

a 

Well. usua ly, I try to be at work around a quarter 

[g!nigh 

ht and I work until - most days, until 7:30 or 8:00 at 

[IO1 Q Do you work weekends? 

1111 A 

Q 

Some weekends, not every weekend. 

[12! How often do you work weekends? 

1131 A Well. I work weekends 

[ 14 1 radio address and it varies over time. 9 

enerally when we have a 

f I know the 

[ 151 President is going to be in, is going to be by himself and 

[ I 6 1 we’ve got meetings or phone calls, then I’ll come in. 

117;But if, you know, right at the beginning, the first year 

[ 1 e 1 we worked, I worked seven days a week. We worked 18,20 

~191 hours a day for at least six months and probably longer 

rzolthan that. 

1;: i eventually was stayln 

And then after that, what I started doing 

[:3;l’d stay until 1190 or 4 

as late as I could on Friday night, 

:z~jfrom comin 

2:00 on Friday night just to keep 

in on Saturday or Sunday. 

t75: c? You made a reference to if the President were by 

Page 42 

(11 himself. I take it you mean if he didn’t have a secretary 

[ 2 1 like perhaps Betty there at the same time? 

[3! A Mm-hmm. 

I :i Betty and 

0 So is it fair to say that there was an effort by 

[6! that over&e it? 

ou to have one or the other of you there? Or does 

A Well. that might overstate it certainly on the 

iz j weekends. One of the things I noticed about Betty is that 

i 3:she liked to come in on the weekends to work rather than if I 

[I o ~wpuld stay late on Friday night ‘ust so I don’t have to, I 

[ 11; think Betty likes being in there b y herself and kind of 

(12 Iworking without a bunch of other people around. So she 

[ 13 1 seemed to come in a lot on the weekends. 

[141 Now, what was the original question here about - 

[lsjwhat did you ask me? 

[I61 Q I was tryin to 8 ure out if there was sort of a 

[::I Ian to have one or the ot ?l er o B you there or was it sim 

(18 1 P hat in your mend there’s more call for you to be there I .P 

ly 

[ : 9 1 there’s no one else there? 

I201 A 

[?:iinstance, if the 

Well. I think we would try to work it out. For 

!? 2. then between t g 

scheduled a meeting on Sunday afternoon, 

e Presidents aide and Betty and myself we 

! 2 3 iwould probably work it out. 

;2;! I mean, normally, I feel like I’m the head of the 

[z 5 1 office and if I can I usually - if I knew that he was going 
1399 

BSA Nancy Hemreich, 6/16/98 XMAXWOI 

Page 43 

i I : to be in at a specific time doing a specific meeting, then I 

(2lwould offer to come in. Or if he had to make a call to a 

(3 :forei n head of state and he needed to do it in the Oval, 

1:; then 9 would first offer to come in. 

[5j But we would - if I couldn’t go In - but oflen, 

[III mean. if there was something scheduled that I knew 

r7! about. then I would - 

Y 

ou 

[ 3: ourselves. And 

know, we wouM discuss it among 

some 

know 

rmes we all would show up and sometimes, 

j jlyou one of us would. 

ilZ!’ Has the President ever called you at home? 

;I,! _--. Yes 

‘11. 

L--. a Often? 

!I?: A 

:;4. Q 

Periods of time, yes, when it’s often. Yes. 

Well, let’s take 1997 as an example year. How 

[;s:often during 1997 as best you can recall would he call you - 

r16jat home? 

[l:: A Once or twice a week, probably. But that - you 

[ 181 kfIOW. I’d have to go back. I mean, I couldn’t guarantee that 

~191 it’s once or twice a week, but, you know, at times it would. 

f20: Q I’m assuming that’s an estimate. 

[21: A Yes. 

122; 0 

[23lfor? 

And what sorts of things would he call you at home 

A Well he would call me about olf a whole bunch. 

[:tiAbout this is Saturday and I want to play go 19 and, you know, 

Page 44 

[I 1 who shoutd I pla 

Q 

with and can I play at a certain time. ,^ LL ! [ 3 j matters? 

Sk of scheduling matters. somewhat social 

A Scheduling. Social. Sometimes he’s done that. 

Iz;“l’rn going to take my wife and my daughter to Easter brunch. 

[ 6 j Where should I take them?” You know, that’s not an 

[ 7 1 uncommon question. ‘We’re going out to dinner, where should 

scheduling but it atso mi ht be 

or if he ran’ into someb J y and’they 

to him and do I remember this or do I 

Or “I saw so and so last nioht and thev 

i:xjsaid this.” 

t14: And sometimes he would call me for phone numbers. 

,I; I If we have a friend in town. he would ask me. “Where’s so 

ils:and so sta ing? I need to ‘call him.” ' 

ii': A It appears that the President, then, would have 

[ I 3 : called you at home much more frequently than he called Betty 

[ig:at home Any articular reason for that? 

[2s: A hell I don’t know that thars the case. I mean, 

12:: ou all might know that you ma 

[~2 ,!ve never paid any attention to t 

[;3imore than he called Be 

!l 

have asked that question. 

e fact if he called me 

ould there be any particular reason 

to be the case? 

Page 46 

il‘ A Well, I thank more like a year, but it might be 

i 2 between those two numbers. You know, maybe more than once or 

i3‘twice a year and less than once or twice a month. 

Cl 

r =’ lettin 

Has he ever asked you to come in for the purpose of 

someone into the White House, for the purpose of 

1 i. WA&-rng someone in? 

i7: A I believe so? 

is: Q He has? 

[5: A Mm-hmm. 

[lo‘ 

illi 

Q Tell us about that. 

A Well - 

Q 

i izi that’s fairly fresh in our mind, at lea’st more fresh than 

Lets focus on 1997 just so that we have a year 

;?‘I:?%. 

i]Sj A 

[ 16 j know, 

The ones that I can remember are either - you 

ma be a 

[ :7 I handled. 5 I? 

ersonnel matter, sometimes those have to be 

ome ~rnes legal reasons, 

[la: Q I’m not sure I’m following either what personnel 

[ 19 1 matter or legal matter would me in the circumstances. 

c20: A Personnel, he needs to interview somebody for - I 

[21]mean. obviously this is not the case - Secretary of Defense 

r22land it has to be kept ve 

[231you know,.everyone an Z+ 

quiet and you don’t want people, 

their brother knowing that this person 

[24!1s coming In because then it’s in the newspaper and, you 

1251 know, basically you may embarrass somebody if this person is 

[ I 1 not picked. 

Page 47 

And so he would call me in there to handle that 

i z i because I can do it in a way that everyone in the world 

[ 4 Idoesn’t see them. Tour people don’t see them coming in and 

[ 5: that sort of thin 

16: Q &d that would be an examole of a oersonnel matter. 

I71 A Right. 

[ai Q 

A 

And then you made reference to a legal matter? 

Well, the same with his lawyers. I think a lot of 

I : ,‘i it would be, you know “I need to get - my lawyers need to 

I 111 come over today, can’you come in and make sure they get in 

I .~~. 1 z : okav?” 

113‘ * And it miaht be friends or sometimes it would be 

i I 4 j “So and so warits to come in for a 

[ 1s ithat?" And so, I mean, a variety o P 

hoto, can you handle 

reasons. 

1161 , , , ,*ipn~=, Q How often has he asked you to come in to WAVE in 

i’Ii...-..--. 

[ia! A Well, I think - didn’t we just discuss that? 

I 19:Maybe - I don’t know how man 

[2o; a dozen, I don’t know tf it’s six, Y 

times. I don’t know if it’s 

don’t know if it’s two 

robably less than two dozen 

know - more than six, so 

Page 45 

A 

ji;miaht call somebodv about would be the thinas that I miaht 

Well probably because of the kinds of things he 

13 i knijw something about. 

I mean, I would be able to handle scheduling 

all the friends. I keep track of the 

does. Because most of the 

from Arkansas, a lot o P 

eople 

them, 

so we basically keep track of 

[ I 3: where someone is. 

might be the one who knows 

Q 

1 f: j to the office? 

Has he ever called you and asked you to come back 

On a weekend for example, or at night? 

[:3: A 

ii:: 

Q 

Yes, I think he has, but - 

It sounds like ou’re a bit unsure of it? 

A Well, I’d have r o come up with a specific, if that 

116: would be the next question, I was already jumping ahead, to 

~17 1 think of when he did it and under what arcumstances. But I 

119: believe he has. 

[19: Q 

r2o:somethin 

Well, sometimes people can be certain that 

~21:mind. Is w 

has hap ened in 

.P, 9 

eneral and not have a specific in 

at the SI uabon WI h vou? 

[2Z‘ 

(23; 

A Yes. 

Q All right. Do you have any impression about how 

r 1 J 1 often that wouM be. once or twice a vear. once or twice a 

i25imonth? 

. 

Page 48 

0 Unusual in the sense that it doesn’t ha 

Ii i often or you’re not sure why he would turn to you to vs%? very 

[ 3 1 someone in rather than someone else. I assume that there are 

[ 4 ] others at the White House and maybe even in the Oval area who 

[ 5 I would have the authority to WAVE someone in. 

A 

176; called me to ask me to do that. 

I guess I never thought it was unusual when he 

to ask a question that 

ed to ask it. 

I 1 o I I assume that the e e-mail himself, 

[ 1; 1 doesn’t have his own computer system an 

112: A I?’ 

hrng like that. 

Q 

He has a computer, but he oesn t handle e-mail. 

I:ilcomputer? 

Okay. What kinds of things does he do on his 

1151 A Well, actually.. he has a computer. I’m not sure he 

[ 16 1 does anything on it. 

[17!itat all. 

He has rt, but I don’t believe he uses 

0 He doesn’t send e-mails to the Chief of Staff or 

I :“, i anything like that? 

120: A Not that I’m aware of. 

121; Q Oka If he wanted to have someone contacted 

~22 !electronically woul 

!23iorwould henotdo!hatata/??y 

he srm I do it through your or Betty 

i24; 

[2il 

A I don’t know that - 

Q Has he ever done that? 

Page 43 to Page 4% OlCStarr 
1400 

Nancy Hemreich, 6116198 XMAX(9Is) 

Page 49 

A I have people who send me e-mails for the 

Ii 1 President but I’m not sure that it was at the President’s 

1; 1 request that they do it. 

[4! Q I see. Okay. Let me turn then to another subject 

:s]area,. Linda Tnpp. Have you had any drscussrons with the 

i 61 President about Linda Tnpp? 

[7] A Not that I recall. Let me think about that a 

[8 ]minute. Well. her name has probably come.up, but going to 

:3]the next part. whether there were conver,sahons about L!nda 

rio]Tripp or what the conversations were or in what contextis 

: 11 ]what I don’t remember. but did her name ever come up in a 

! :Z 1 conversation with the President? 

i13! 0 Can you t 

Probably. 

: 14 1 happened, who else was r here. how it arose, wha 

to reconstruct as best ou canwhen it 

ty was said? 

A Well. I’m not - I don’t know. It might take me a 

i:z;while if you want to give me some time and let me think 

: 17 labout it. Certainly she - but really - I’m trying to even 

: 18 1 remember if at first - I know she worked - Bruce Lindsey 

rls]initially was a part of our office. even though he was 

~~~~Director of Personnel. 

1111 And so I hired a woman named Deb Co lebt;p one of 

~33 ]the President’s secretaries with Betty Cunie. but CIe 

[33]like Bruce needed more help, which he did, than the President 

(34]did at that time and so Deb drd a lot for Bruce. put then 

[zs]when she was gone sometimes she’d bring in Linda Tnpp. 

Page 50 

iijphone or - possibl that. But 1 

Q We{ let me be a bii more direct because I’m less 

$iinterested in whether you might have discussed Linda Tripp’s 

ts]typing speed than in whether you ever discussed Linda Tripp 

[ 91 in connection with, first, Monica Lewnsky. 

1101 A I don’t believe that I ever discussed Linda Tripp 

[ 111 in relation to Monica Lewinsky. 

! 12 1 is jumping ahead of 

It is my recollection, which 

ou but, believe me, I can.be wrong 

!;3]about this., that the fy irst time *. I knew of any relationship 

i14 ]was possibly when one of these news accounts came out. Now, 

115 1 Iwouldn’t swear on a Bible, which I may have done that, 

i 161 but - but that’s my recollection. 

Q 

i:iiin connection with 

Didru ever discuss with the President Linda Tripp 

i19i 

athleen willey? 

A Well. that’s what I’m trying to reconstruct in my 

(:o]brain! whether - if I ever had a conversation with him post 

tzl]that, It would have been in relationship with -you know, In 

[:zlthat context with Kathleen W~lley and I don’t recall a 

~33 IS cific conversation right now, but I’d be glad to think 

(24 1 a&t it. Because they worked - Linda Tnpp and Kathleen 

irsjworked together in the counsel’s office. 

Page 51 

I would more associate Linda Tripp with Kathleen 

I: i Willey because the 

I 3 I Lewinskv. Maybe & 

worked together than I would with Monica 

onica and she worked together, but I’m not 

i 4 j sure I wis aware of that. 

[51 0 All right. Think on it, if you would. 

[61 A 

0 

Okay. I’ll be glad to. 

I’m going to ask similar kinds of questions about, 

iiifor example, discussions between you and senior staff about 

(9 1 Linda Tripp and Monica Lewinsky. 

101 A Okay. 

111 Q 

A 

Have you had such discussions? 

Well, in what way? I think - you know, sometimes 

:: i you might have general conversations with people because of 

14]what ou read in the paper or whatever, but I don’t recall a 

I SISWC i)! IC conversation I’ve had with someone about Linda Tripp 

i;iia’nd Monica Lewinsky. 

[I71 Q 

A 

Did you ever discuss it with Bruce Lindsey? 

:ial Linda Tripp and Monica? Not that I recall. 

iI91 Q What about with senior staff relating to Linda 

[30 ]Tripp and Kathleen Wrlley? 

I'lj A I don’t recall one. but that’s not - you know, 

[ 2: 1 again, that one would be more likely and that would be the 

[:3jone I want to make sure about and that I’d have to think 

124]about for a Ion 

.?I 

while because. again, that’s where my 

125 1 association wit Linda Tripp is. 

OlCStan 

Page 52 

Q Let me be ‘ust a little more directed, then, rather 

Iiithan just sentor staff, wha 1 

[3]panicular? 

about Bruce Lindsey in 

14; A Linda Tripp and Kathleen Willey? 

[51 Q Mm-hmm. 

161 A 

i 7 j that. 

Actually. I do think I did talk to him once about 

Q Can you give us your best recollection of that? 

/:;Where. when. the circumstances who said what to whom? 

A Well it seems like’there was some sort of a 

/ :y \conversation about’whether Linda Tripp ever called him and 

ilzjwhether he - 

[13] Q Whether Linda Tripp called Bruce? 

Yes. At some point. And whether he ever returned 

- I m uncertain of that, 

And, ou know, this has serious repercussions and 

t:!,iso I don’t want r o say something so flippantly that would, 

Page 53 

is_jthey askedme that. 

Q Who at the White House Counsel’s Office would it 

15 i i have been who was talking to you on that subject or those 

[zs]subjects? 

Page 54 

[zz]Willey. Was it ‘97, ‘96, ‘95? Who knows? 

(231 Q 

[24 ]for 

All right. Then let me sug est a sub’ect matter 

Y 

ou. Did ou ever have an athleen 

[25]Wl ey about K-r- 

‘r; conversa 9 Ions wlh k 

ichaet Isikoff, a ewsweek article, about 

Page 49 to Page 54 
1401 

BSA Nancy Hemreich, 6116198 XMAXI1OHOl 

Page 55 Page 58 

: : : Kathleen Willey possibly being approached by the President in 

I 1 an unwanted way7 

.3 A 

4 : what 

By the President? Well, you’ve asked - tell me 

ou’re askin 

: 5: camp y rcated ques ? 

me there because you’ve asked me a 

Ion or a compound question with several 

:;:parts. 

._. Q Objection sustained. Let’s put it this way. 

f 3 i Michael lsikoff did research on a 

: 5 i to whether the Prestdent had 

ossible article relating 

ma $ e an unwanted gesture.. let’s 

: : :!caII it toward Kathleen Willey. He did some research dunng 

: 1: jearly ‘97 and there was an article that came out in the 

12: summer of ‘97. Did you have any discussrons with Kathleen 

: : 3! Willey about that? 

. . A 

j :; i compound 

Well. I’m not sure - you’re still - it’s still a 

uestion here. I had a conversation with Kathleen 

: 16: Willey abou 8 a call or that somebody was, trying to - some 

; : 7 1 sort of news person of some sort was tryrng to approach her 

: : 3 1 In some way. 

.._. .-3, 0 What can you tell us about that? 

:33: A 

“1’ .- , Q 

That’s about all I can tell you about it. 

She called you? 

‘1?1 _--, A She called me. Mm-hmm. 

:231 Q Wh would she call you about that? 

A Wel r she - I think I was the person that was left 

izliat the White House’that she felt closest to. 

::; Q 

‘2 I about? 

Drd you have an impression of what the call was 

MR. WlSENBERG- Could I just ask. are we talking 

I: i about the call from the reporter or the call to 

[ 5 j Ms. Hernreich’ ..n r . . . . 1-1,. ..1_11 II- *_ .__ ._ r- __ _ ..I... L-I 

[6j Mm. CMMIClK. vvek. r,m rrymg to ngure our wnar 

[:I 

Y 

ou understood Kathleen was talkrng to you about regarding 

13 1 he call from the re otter. 

‘4; THE V&NESS. 

iii 1 reporter was about to her? 

What I understood the call from the 

[i:: MR. EMMICK: Yes. 

[I:’ THE WITNESS: 

::3itell me, as I recall. 

I did not ask her and she did not 

i ! ” i BY MR. EMMICK: ...A 

;I51 Q 

A 

Well, was she looking for advice? 

!i:jadvice. 

It did not appear to me that she was looking for 

i?3! 0 

A 

Was she thin you and the President a heads up? 

[I51 I got the .8 I ea t i? at she was informrn me. 

1201 Q And what was she informing you o 8 

[211 A 

r??lherThat someone was calling her wanting to interview ves. Interview her. I auess. since it was a news 

j--l I-- .” 

[;3iperson. 

Q Someone was calling wanting to interview her in 

I:z;connection with the President? In connection with the White 

Page 66 

Q Well, if all it was was a news person trying to 

iiicontact her in some way why would she call ou? Presumably 

:3 1 it had somethin 

\It 

to do whh the White House, ! take it. 

ell as I remember, she wasn’t specific about 

iljthat. That; as I recall it. 

:ij: Q What was the news person asking her about? 

:‘I A I donY think she told me. 

:?; Q It’s hard for me to get a feel for what this 

: j;conversation must have been like. She calls 

Y 

ou and she says 

: 3: “A news 

:: jfill in the 

ersons contacted me about -)I and hen could you 

g lanks for us7 

.T. A Well I don’t think she told me. I don’t think 

:; jthere was any blank to fill in. 

14: Q Was it a long conversation? 

1 5 : A Not that I recall. 

:<. 0 Could you give us sort of a best estimate of how 

:- 1 long you think the conversation was? $’ .-“. A Certainly less than five minutes, but maybe even 

a 1 shorter than that .--.- ._^. Q What seemed to be her emotional reaction to the 

1 I: x call from the news person? .__): A Kathleen always seemed to be pretty calm in most 

-1 j 1 circumstances. 

._.. .-_I. Q So she seemed to be calm? 

A Seemed to me. 

Page 68 

[I 1 House? In connection with her children’s schooling? There 

! z 1 must have been some reason that she was calling you or 

[ 3 1 someone associated with the White House. 

[41 A ain. as I recall, she did not tell me. 

Q 

Well, a 

All ngh 9 

Iz 1 of a heads UD or to aive YOU infonnation. 

So she was calling to give you a sort 

i71 A ’ That’: as 1 recall it. 

Q 

! 8; to ask. “Gosh. what was the reoorter askina about?” 

Okay. What was your reaction? Were you interested 

.- 1 

1101 A ‘No. 

[Ill Q 

[I21 A 

[ 13; not ask her why she was calling me, that I recall. 

1141 Q Did anv other names come UD? Did Linda Trio&. 

ilsiname come up? _ 

. 

iI61 A Not that I recall. 

[?71 Q 

!18] 

Did she ask at-41 questions of you? 

1191 

; Wht: Kathleen. 

113; A Not that I recall. 

Q And after you got this call that you think she was 

iii i trying to give you information about. to whom did you tell 

133lthis informaiion? 

I241 A My recollection is that I told the President that 

[35:she had called. 

Page 57 

What would have rompted her to call, then? She 

: 2 ; gets a call from a news e’s calm about it - 

.- 1 she would have called me. 

et that same information 

--7, 

fE;jabout? 

Q What did Kathleen Willey tell you the call was 

.- ., A 

:i;jwas about. 

She did not, that I recall, tell me want the call 

Page 60 

:11 Q And what did you tell the President? 

I21 A That Kathleen called and said that there was a 

! 3 1 reporter who was trying to talk to her or interview her or 

j4~something. 

j51 Q And why did you tell the President? 

i’m noi certain if Kathieen asked me io iei him 

1 s i know or if ?did it sort of as chatting Well toda 

! 8 1 are the 

P 

hone calls I got and this is’what 60 an rF 

these 

so said.” 

[pIAnd so don’t recall. 

[IO] Q And what was the President’s reaction? 

A I think and I’m uncertain of this too but this 

I ii iwould have made sense to me, is that he told me to tell 

[:31 Bruce, to let Bruce know, or maybe he, you know, Well, why 

j141don’t you let Bruce know.” 

1151 Q 

A 

Did you jet Bruce know? 

i :t 1 not have said 

I think so, but I can’t guarantee it. And he may 

[ 1s Ishoulders. 

anythin 

I don t rea w, 

he may have just sort of shrugged his 

y recall. 

[I91 Q 

[201 A 

Would you have let anyone else know? 

Well, I might have let the press office know. 

[?I1 Q And who at the press office would you have ad vised 

[xlof that? 

I231 A Whoever I could have otten in touch with. 

Q 

IZ:jin particular? 

Do you have any reco a e&on of speaking to anyone 
0% 

Page 61 

1402 

Nancy Hernreich, 6116198 

Page 64 

11: A I don’t have a recollection of spealcrng to anybody 

[: 1 in partrcular about it. 

Q And what would it have been about Kathleen Wiley’s 

1 j; call that would have been suitable or appropriate or would 

1 s J have called for lettrn the 

?t tp 

ress office know or leang the 

[ 6; Presrdent know or le rng ruce Lindsey know? 

i-: A Well, what would it have been? You’ve asked again 

i 9 1 three or four different things there. I mean, are you asking 

[ 91 as a group or as - 

1 o 1 person was interes 

y.. ou know why - because a newspaper 

Q 

ed In rntervrewrng somebody.. 

Okay. Somebody formerly assocaated with the White 

:i j House? Is that the thing that made it worthwhile? 

‘7‘ A Well. I ouess that was mv assumohon. is that that 

; 4 i had somethingto~db~v%h the White House or rrta be ‘that’s wh 

15 1 she called me and so I should inform somebody x at she shou Y d 

16; call. Or it could have just been - I think I let somebody 

I 7 ! know that for that - 

Page 62 

Q When she made this call to you, did you understand 

t:ithat it had something to do with an unwelcome advance that 

[ 3 1 the President had made toward Kathleen Willey? 

I41 

IS! 

161 

A No. 

BY MR. WISENBERG: 

Q Or an alleqed unwelcome advance? 

i7j A No. - 

[81 MR. EMMICK: 

[ 9 1 on that sub’ect area. 

All right. I have no other questions 

IlO! 5I 01 or any of the grand jurors? 

. . ..D 

111, ,“,rx. 

MR. WISENBERG: 

cl-lend. 

I might later. I’ll wait until the 

131 MR. EMMICK: Okay. 

14! BY MR. EMMICK: 

Q Let me ask, then, a uestion in another subject 

:,‘i area. Any knowledge that you mi h have of any job efforts 

17 1 taken to get Monica Lewinsky a JO ‘89 in the follows na three 

ia Icategories. One would be in connection with the .N. Any 

IV! knowledge or information at all about efforts by anyone to 

:o laet Monrca a iob at the U.N.? iz:;- A . No. 

Q What about to get her a job in private industry in 

IiiiNew York City? 

[24. A No. 

[25: Q What about to get her a job back in the White 

Page 63 

[ I ! House? 

A No. Well let me .ust make sure of that last one. 

i; j At any time, a job back h the dite House? 

[4i Q Right. 

A That one I may have had some awareness of. When 

i 2 i you say that, to this point, it had never dawned on me, but 

~7 :just how you said that, whether it was Monica or someone else 

[a Iwho ever left the White House, people who leave the White 

[ 9 I House all seem to want to come back at some pornt. 

And so whether s ecificall 

11 P j who ever left and called an 

( 11; or “I’m t in 

8 said “&I I’d love to get back’ 

Monica or somebody else 

[ 13 1 if she ca r8 le 

to get back at the White House,” I don’t know 

me, but I may have had some general awareness 

I 14 I of that. but I can’t be soecific or I can’t auarantee that I 

ilsjwas aware of that. 

Q Well then let me run through a lit of names and 

i :7” 1 see if that helps ‘og’the memory. 

[ia: A Okay. 

I191 0 Did you have an discussions with the President 

I 2 o I about brinaina Monica back to t g e White House? 

i2:i & -No. 

[22] Q What about with Marsha Scott? 

1231 A No. 

[141 Q When you think about brin ing Monica back to the 

[ 15) White House as a concept, let me sugges 9 that she was 

: Interviewing at the hahonal Security Councrl for a whrle 

I Does that jog any memory at all’ 

,: A No remo of that. 

Q 

:i-Mr. Nash? 

All right.. X hat about wrth either Mr. Halley or 

; A No. I don’t recall an 

I’- those people about Monica Lewins ): 

conversations wrth any of 

i 5 :you’re askin me? 

y and a job. Is that what 

.; 

. . M% EMYCK: Yes. 

I::‘ MR. WISENBERG: 

1: : conversations. 

Or if you heard about any such 

[I:‘ THE WITNESS: No. Not that I recall. I don’t 

: .~~ : I. remember ever hea?na anvthinq about robs with any of these 

! :: : people. 

_ _ - 

[:I BY MR. EMMICK: 

[:c: Q Nex: I’m going to ask about a phone number 

[:-’ 

115: “0 Okav 

A Well. I think it’s mine but I can’t uarantee it. 

1: :[ It’s one of mine but I don’t pay any attention to 9 hat 

[z:‘number because it’s not the number that I give out. So - I 

r:::think it’s mine, but d could be somebod 

122’ Q x 

else’s in there. 

ic:l 

It’s our impression that ‘s yours. 

A Okay Good. 

125: Q It’s not a number called as frequently as the other 

Page 65 

MR. EMMICK: Just a minute, if you would. 

~‘~&AMlCK: 

Q 

A 

Did Kenneth Bacon ever call you? 

Not that I recall. 

[i-I 0 Would he have called you to get a hold of the 

;;;; President ever? 

A Not that I’m aware of. 

[z:: Q The reason w ‘re asking is there are records of 

[ 2:. calls from his office to you r& I believe number and 

rzz:we just want to make sure that since the DOD number is 

(:z : one shared by Monrca Lewinsky and Ken Bacon, we’re trying 

1:: : to make sure that its a Monica call rather than a Ken Bacon 

[‘s:call. 

Page 66 

;:: A 

i I ‘about an 

F’ 

Well. I don’t recall ever speaking with Ken Bacon 

: 3 1 know tha 

hrng, honestly. I may have me4 him, I don’t even 

I ve ever met him, but I may have. I probably 

1: : have, but I ‘ust don? remember. _ _ 

.: d It sounds like you’re sug 

i 6 : calls from that number they’re more like 9 y to be calls from 

esting that if there are 

: - : Monica than they would be calls from Ken Bacon. 

!?: A I would think so, but it’s not out of the question 

! 9: that he would have called and I wouldn’t have known about it. 

11 c :To that number. 

11:: Q Okay It doesn’t sound like you r 

[ 1:. likely, when you sa 

-b 

out of the question, it’s sort “3 o

ard it as 

[ : I : everything is pass ie. 

A Well. I would think that eventually I would 

i if ’ have - that name would have crossed m 

[ 1; : or something from hm. but, again, it’s no Y 

desk with a message 

out of the 

[I-:question. 

[ii: Q Do you have any recollection of calls from Monica 

i! ;.to vou? .--:- ,-- 

[ZI: A No. I do not. 

Q If Monica had called you to speak to the President. 

I;jjwhat would you have done? 

[;3: A What would I have done? I don’t know what I would 

[2“have done. I would have taken a message, I guess. I don’t 

[zs:know. 

Page 61 to Page 66 
1403 

BSA Nancy Hemreich. 6/16/98 

Page 67 Page 70 

‘II I don’t ever recall her calling me to speak to the 

; 2 1 President, so that’s kind of a - I don’t know what I,would, 

y 31 have done, frankly. Especial v - I mean, now you re askmg 

[ 4 1 me in retrospect rather than a the ttme, but I probably - I 

! 5 Idon’t know. Just taken a messa e. 

ossible that I,! omca would have called you to 

because she was having difficulty 

Can I tell you a IitUe bit about that 

I?! A itis a pubiished - ii’s the number thai’s out, i 

13lthink. on all the books and everythin 

14 1 number. I never answer that line, it %, 

so rt’s like my phone 

oesn’t nng on my 

15ldesk. I don’t see it. It goes to Rebecca’s desk and it only 

; 16 j rings on her desk. _ 

ii71 0 So it’s possible that Monica was trying to get a 

: 1 J 1 hold of Rebecca? 

i191 A It’s possible. 

1201 Q And it sounds like certainly Rebecca would have 

izllbeen the person to answer that line. 

Rebecca or the intern would have answered it. 

~~:~Or sometites Janice Keamey answers it. Whoevets back 

124jthere. 

(25) Q Do vn,, know whether R&m or the jntem knew , _ _ . . _ . . . - _ _. _ 

Page 68 

[ 1 j Monica? 

A Oh I’m - or I say I’m certain. I’ll back up. 

I:;Yes. Rebecca knew her. 

I l i had 

Q 

called 

Well, did Rebecca ever report to you that Monica 

for example? 

[61 A Well, not that I recall. 

171 BY MR. WISENBERG: 

[El Q 

A 

Does- ring on Be 

Eventually it WIII roll. F 

‘s desk? 

ventually, if it’s not 

i iilanswered in the back by Rebecca and I don’t know if it’s six 

! I 11 or twelve times that it rings in the back on Rebecca’s desk 

: :2 1 before it rolls to another person in the complex. Since it’s 

~13 1 one of the published numbers, then we try to answer it. But 

: 14 1 Ithink it rings on Betty’s desk eventually, but like either 

c i 5 1 after six or Twelve rin -s. 

1161 BY MR. Elj(MICK: 

Q So if you’re in on a weekend and somebody calls 

i:i ‘I it wouldn’t rinq on your desk and you’d have to 90 out 

119 jmebecca’s desk iii order to answer the phone? 

A 

Iz!lbit away so - 

Yes. Rebecca is down the hall from me and quite a 

well, we also have a thing if it rang up to 

lx 1 Betty’s desk, I can hear the phone on Betty’s desk and I can 

r23ldo star 7 and pick it up, which is if I hear her phone ring 

124 land I want to answer it then I can do star 7 and 

P 

ick the 

[:51 number up. So it would eventually roll most like y to 

:I! know anyway, righ_t, 

.-_ MR. WISENBERG: 1’11 look at the record 

: .-. THE WITNESS: All right. 

7 BY MR. EMMICK: 

:j: Q I wanted to ask a couple of quesbons having to do 

: 5 iwith calls to you from Vernon Jordan. 

._: 

i?; 

A Okay. 

0 You had mentioned I believe, earlier that on 

: 5:occasion Vernon Jordan had called 

: ;;I he does call you he’s calling for the 6 

ou and that ordrnarily if 

resident. Is that a 

:::;fair summary? 

. . . . . . . . . 1 _I . L -- 1 well, 1 tnmk - weii i don? know ordinariiy. i 

:: 3 1 would say?naybe that’s - why don’t we say - and that’s 

:: J 1 throwing rt out there - 50 percent of the time or maybe even 

: :j:less. I wouldn’t say ordinarily. 

Q You mean so sometimes he just calls you to say, 

liti”Hi. how are you doing?” 

[iSI A Well, he may have a messa 

:; ~1 He may ask me, you know, what the Pres &f 

e for the President. 

ent’s schedule is, 

[-rJ! he may sa 

~3: 1 from me a il 

- I mean he may just want to know something 

out something that’s going on in the White House. 

::z! I mean, it could be a variety of reasons, you know. he might 

:33!call me. 

i241 Q Does he call often? 

i?Cl L--1 A Not any more: 

Page 71 

ill Q Part of the reason I’m asking is we have some phone 

[Z 1 records and the phone records indicate the calls from Vernon 

[3j Jordan startin 

!4 1 consistent wit % 

only in November of ‘97 and that doesn’t seem 

!5j 

what YOU had said - 

A Un-uh: 

!6i Q And so - well, that’s the reason that I’m asking. 

!71Does thatyn;e;ong? 

191 

Q Okay. Tell me how wrong it sounds. You’ve been 

iii!speaking with him you know whatever, a couple times a month 

!:I {for vears and vea& and vears - 1.~1 I 

r-71 A -Let me just -there were a few - six months or 

t;!so, I guess, where I thought Vernon was 

;14 1 because I had chided him once on somet E. 8, 

robably an ry at me 

rng and so e sort of, 

: 15 1 Ithink, talked to Erskine or to other people around there 

::ijand quit calling me uite as much. 

:1:1 Q Whit Il six-month period would that have been? 

:. II?] A I don’t know. It’s been a long time ago. I don’t 

[lglthink it was in ‘97. I think it was pm-‘97. 

:231 

:21: 2 l?#that hard to believe. I think you should 

o back and recheck the hone records. I cannot 

at those calls started in Fp ovember of ‘97. There 

solutely nothing to ex lain that. Now, 

1-5 lat maybe - he may be cal P rng - do you loo z 

ou’re looking 

at all of my 

Page 69 

[I ! Betty’s desk and then I could ick it up 

17, BY MR. WISENBE 8 G: 

L-1 

Q When you 

I: i you able to look in your ca 9 

et a call from outside the complex, are 

ler ID and tell who it’s from, 

[sjwhat number it’s from? 

A Well, if it rings on my desk, I can. But if it’s 

1 t1 not ringing;n m 

i31 ry 

desk, I can’t. 

o you know whether or not if somebody called a 

[ 9 1 number such as the Rebecca Cameron number and then it rolled 

10 1 over, for instance, to yours or Betty’s desk. whether or not 

I 11 the person at vour desk or Bettv’s desk. lets say. let’s sav 

13 j Betty’s desk ii rolls over there,wouid be able to iook and13 lget a caller tb on where it was coming from? 

141 A 

lslrin 

I’m not sure. I don’t pay enough - it doesn’t 

!I 

- when it rolls, it doesn’t ring to my desk if it rolls 

16110 W’S. 

Page 72 

: 11 extensions? I mean, there’s another one which is B, I 

! L 1 think. He may have called me on that one. Did you check 

.3 1 that one? You’re welcome to t 

i41 Q We tried to, but r et’s - 

:5’ A 

:E’ Q 

:7; I’m asking. 

I can grvep a number there. 

We II the It out. I mean, that’s the reason that 

It seemed unusual in light of what you had said 

! 3 1 and I wanted to check with you. 

::$aemed to call. 

Can you give us a best estimate of how often he 

!11] A 

[1?] 

2 

t-$;. often would Vernon call me? 

Well we’d go through periods of time - once or 

:i: itwice a week sometimes. Once or twice a day sometimes. 

:: 5 1 Sometimes five times Sometimes once a month. 

::6] A lot of it de 

: ;- 1 and a lot of that proba 

: ; 5 1 and where he’s going 

: 131 to Asia or some place 

;:almuch. 

Q All right. I have to ask what prompted him to 

j i: i call five times in a da 

A I don’t Ii 

if you remember? 

now. Let me think about it. What would 

il:icauseL;mz ,~tl? Obviously that may be an exaggeration, 

.-=lhfilr - . ..v._ _ :. .a_ -okay. I at InP nive “ml an aramnle i_‘1”“. .__. . ..” =..” ,_” “.. -^‘...r.-. !f 

Page 67 to Page 72 OlCStarr 
1404 

ESA Nancy Hemreich, 6/16/98 XMAXIlYlJ) 

Page 73 Page 76 

: 11 he was out of town and wanted to speak with the President and 

I 2 ! the President was unavailable but there wasn’t a number where 

I 3 I we could call Vernon back on or somethina - 1-1 

j4; Q Just being persistent. - 

15i A Yes. So - and that’s a possibility. And i~_L__:____l__ .L_.__._I> L^ ^ ____#_.^ ^_ ^__^_^L :^_ L^ _^.. L ^..^ ! 0) “““,O”Jl rr,ac WUl” IJe d y.Jrr’pIe:le IId 

T 

CIdLI”II, IIC IIld Ildve 

L 7 1 never ca led me five trmes In one day. I? aybe the most h e 

~0 1 called me was twice. I don’t know that. 

191 Q Dd ou ever talk with Vernon about Monica? 

IlO! A Not & at I recall. 

ill1 0 

[??j A 

Drd her name ever come up at all? 

Not that I recall. 

113: 0 

i I .I : friends? 

Dtd you know that Monica and Betty were close 

(151 A No. I did not know they were close friends. 

1161 Q DK! you know they were friends? 

[I71 A Betty is a friend to everyone. Eve 

~1s 1 friend. And that’s not, 7 

one is Betty’s 

ou know, meant facetious y or 

[ 19 1 exa 

[zo] real ? y. 

gerated, but I thin z Betty is the mother of the world, 

I mean, she - everyone loves her and comes to see 

[ 2 11 her and calls her. 

Q Did you have the impression that Betty was closer 

l::ifriends with Monica than she is with everyone else in the 

[z4lworld? 

[251 A No, I did not have that impression. 

_ 

.-: Q We’ll ‘ust take rt a little piece at a trme. We’ll 

i?!startwith Monica. M onica ot a subpoena Did you have any 

{3jdiscussions with anybody a 

c+, 

i J 1 the Paula Jones case? 

out Monrca getting a subpoena In 

!51 A Not that I’m aware of. Not that I remember. I -.2--I. _^^^ II ^..^_ L^..:-^ ^ ___.._ -_.:__ ___:*I _-..I___.. ,6!““II I IeudII e”e?r rr~“lr!y d cuII”~lsall”rI wlr”, anyooo 

0 Did you overhear conversations? WY 

ii j that Monica had been subpoenaed? 

ere you aware 

191 A I don’t think so. I real1 don’t thank so. 

I101 Q What about Kathleen Willey? 

{il; A I don’t know. I mean, the trmrnq of all this, 

r:;!you’re asking sort of ahead of time, you know. You know, 

: 13 Iwhat ou end up reading in the paper since then - there 

; I 4 1 posse ,b ly could have been. 

il5l It seems like there was something In the papers at 

[161some oint about Kathleen Wrlle 

i17lbeen t F 

and it may have just all 

IS sprrng, but I don’t reca x a specific conversation 

(18 lwith anybody, especially around that time, about them getting 

[lglsubpoenas. I just don’t recall it. 

Q Similarly a question about sub 

iI:jto Linda Tripp. Any discussions about that? bid that * 

oenas or a subpoena 

[zzlsubject come up 

rz3lWhrte House? 

in any discussions in the Oval Qffice, the 

[241 A I don’t think so. 

[251 Q Okay. Similar question about an affidavit that 

m___ -1 

rage f4 

Q Qka 

I: i subjects that might r, 

I’d like to ask some questions related to 

ave arisen in connection with the Paula 

[ 3 1 Jones case and whether you ever discussed these subjects with 

[ 4 1 others. 

On December 5th a witness list in the Paula Jones 

Iz; case came out and there we’re lots of people on the witness 

t 7 1 list. Did you ever have an 

[ 8 1 let’s call It December of ‘9 r 

discussions with anyone in - 

or January of ‘98 about that 

[ 9 1 witness list? Who was on it, who the people were? 

I101 

ill1 

; ;t3tl. can you tell me who was on it? 

[121 4 Qkay. I don’t know .is my, answer, then. 

!I31 0 Okay. I mean, so the sublet2 ot witness iist 

[ 14 1 itself didn’t come up? 

A j:z IdoesnY just rin I don’t know. You know. it possibly did. It 

a lot of bells in m 

?t strikes me that i r. 

brain. 

Q in a lawsuit involving the 

I :i 1 President of the United States a witness list had come out 

I I 91 with pa 

[: o J been P 

es and pages and pages of witnesses it might have 

o some interest to those working with the President in 

12 :1 the Oval Office. 

:??I L-.-1 A I just don’t recall who was on it or whether it was 

-_ .._.. __:_I :. __-_ ___A ___I __A _1.L_& ! 2 3 1 puorrsneo wnrcn was - you s*ro I[ c.+irne OUI ano pan or mar 

134 1 could be, you know. whether it was in the newspaper? 

[25j 0 No, no, no. Then we’d be more specific. The 

____ __ 

rage II 

[ 11 Monica Lewinsky was sup 

.p” 

sed to sign. Did the subject of 

~3 1 Monica signing an affidavr come up in discussions that 

r3lyou’re aware of at the White House? 

A 

I l; recollection of. 

No. Not that I’m aware of. Not that I have any 

0 Okay. Do you know what Betty’s phone numbers are 

i76ithere at the office? 

[Bl A 

rs!to - 

No. No, I don’t, actually, because I end u 

I can never remember her present phone number. P 

having 

[ 10 1 really can’t. 

1111 Q Do you know what the presidential aide’s phone 

I 12 Inumber or ohone numbers would be? 

i13; A I do not know. i have an intercom system. I don’t 

[ 14 Ieven know what that IS. I have them all on - you know, I 

1151 holler at Betty through the wall. 

0 All right. Okay. Does everyone there in the Oval 

i :7” ]0ftk.e have an answerin machine? 

i?Bi A Well, no. 9 think they all are part of the system, 

I 19 I an Audix system that, you know. is internal - I assume so. 

iZo]l don’t know. 

Q I meant sort of the concept of an answering 

[I: i machine, not whether it physically has a Radio Shack set up. 

[231 

A I ---..-- _- L .I. A--I. 6 __ &L_. I assume so. our I oon I know mar. 

i241 0 

[25! A 

Okay. Does everyone have caller ID? 

I don t go in and look at their phones. I assume 

Page 75 Page 78 

! 1 lwitness list went to Mr. Bennett and then it was made aware 

[ 2 1 to the President and I’m just trying to fqure out whether or 

[ 3: not there were discussions that you were aware of pertaining 

[ 4 1 to that witr+Asss /sts 

[5I Q .I_ __I_______ __ _~._>_____ _._..I :I :_ _,~__..__:___ r40 rererences or excnemenr aDou1 II In alscusslons 

is i with Bruce Lindse 

is1 A 

the President, anyone? 

We 7, I, you’re making an assumption that I knew about 

r9lthi.s. which is why I asked you was it published and I think 

[ 10 lyou just told me rt wasn’t. 

ill1 Q Correct. It wasn’t. 

A Okay. If it wasn’t published, then chances are I 

i :: i didn’t know anythrn about it. 

Q Rigt!. U n I ess someone had talked to you about it 

I : l i or had mentioned it to you, which is why I’m asking the 

[ 16 1 question. 

[I71 A Yes. And I don’t recall that. 

Q All right. What about an sub oenas to either 

::“9; Linda Tripp or Monica Lewinsky or Kath I een &illey? 

I201 .A 

:211 

i221 

[I?31 : 

A 

Iiz 1 Linda Tripp? 

Subpoenas? _ 

Any discussions - 

Drscussions? 

about subpoenas to those persons? 

co it’s Monica? Who did you say? Kathleen Wrlley? 

i I 1 so, but I don’t know that. 

0 

I: I residence? 

Do you ever call for the President when he’s in the 

[41 A Yes. 

[51 Q Do you know whether the President has ever called _. L-_--n 

L 6 1 %iy interns ar nome I 

[71 A I don’t know if he has. 

I81 0 Do qou know whether the President has given any 

[ 91 gifts to any interns. 

[lOI A 

Q 

I don’t know right off the to 

F 

of my head. 

Cl11 Do you know whether the resident has had any 

[ 13lmeetings with an 

[13lOffice or the stu dy 

interns individually, either in the Oval 

y? 

1141 A Yes. Ido recall. 

ilsj Q Tell us. 

A Well I remember at 

! i: i met with before. Ahd this is a youn 

I 1~ lwent to Georaetown with him and s 

ilgjsome time ari?d I think when she was 

[?o]law school that she went in and talke 3 

etting ready to go to 

to him for a few 

r3llminutes. 

[22] Q 

A 

Is that the only one that comes to mind? 

That’s the one that wmes to mind right off the 

i::ltop of my head. There may have been other interns that we 

135jhad specifically. And other interns who have been in the 
1405 

ESA Nancy Hemreich, 6116198 XMAX~14l14) 

: 1. White House. ,^ 

Page 79 

We’ve got a oun 

j <. interestrng St02 -- wen r to t Z 

man right now who - it’s an 

e University of Arkansas who 

: 4 has sort of mo eled his life after the Prestdent and there’s 

: 5. a possibility that Warwick has been in there. So, you know, 

‘5’ fi’s cettalnl in the realm of 

._. r; 1 

ossibilities, the meetings. 

:5: 

:3 

. . i_. ,^ _L 

A 

Kris Engsko 

Engskov is how you pronounce it. 

Q Engskov? 

A Engskov. Uh-huh. 

Q 

A 

All right. Let me show it to you - 

Well, I pronounced it Engskoff for a while, too, 

: 3: and I was corrected. 

Q All right. When he took ove: - I guess he took 

r; __ ’ over Goodin’s position? 

. r. _ c A Ste hen Goodin’s? Yes. 

-7. Cl Dityou train him? 

13: A No. 

I>- 0 Okay. Did ou ever tell him anything about his job 

2 ::: at all? Are you a person w ‘c o IS advising him? I mean, 

1: : you’re his supervisor right? i^. 

-_ A Well, km sure I’ve told him - I’m sure we’ve had 

i :! 3’ conversations about his job. 

Q 

Ii: j area is a very 

Did 

priva r 

ou ever tell him that the President’s study 

e area and that in general he shouldn’t 

Page 80 

[ 1: be going in there? 

._. 

,-. A I don’t recall tellin him that 

[i: Q Is that the kind o P thing that you would have told 

!::him? 

A I guess so. I can’t imagine sayin 

i i1 that, though, because I don’t feel that way abou P. 

it just like 

it. I 

; 7 f mean, so - I mean, it’s a private area, but I just - you 

; s. know, it doesn’t seem like - it’s not necessarily how I - I 

t 3: mean, the President goes in there and sometimes we have to go 

::‘let him know about meetings,, so, ypu know - now, tell me 

:: : what you’re asking again? It s a private area and - .^. 

--. Q Right. I uess there were a couple of parts to it 

14 : was a private area and then a 

:3 -One would simply have%een T you tell Kns Engskov that tt 

art of that would e in 

1: connection with tellin him tha it’s a private area, did you 

: E: tell him that you shou 9 dn’t be going in there. you know, it’s 

:- : the President’s area, it’s not your area? 

Ii- A 

15’ es 

Well, I don’t - I can’t imagine - the first part, 

The second part, I can’t imagine that I said it just 

zzixke’that. 

:1: Q Oka 

_- 

--. A Butt Y; at doesn’t mean someone didn’t hear it like 

:i-that. 

:_; Q Right. Right. You mean Kns may have interpreted 

: 5 -your use of the word private area to mean that he shouldn’t 

Page 81 

: 1. head in there. 

,_: A Mm-hmm. Well I do tell people in relation to that 

i < i area that it’s not an area that I like to do - I don’t - 

:; : sometimes peo le doing a tour of the Oval office, that I 

! 5. don’t like to do P ours back there. I think there are certain 

15. Q All right. Now, is that more when the President’s 

‘... - *. not there or when the President is there? 

_. 

--. A I think I feel about it both - both times, both 

21: when he’s there and when he’s not there, that there should be 

2 3 : some space that is yours and is private and you feel like 

;::you’ve got a place to go that is ours. 

15: refiects much more my own 

But that, again, 

fee y. ings about my need for privacy 

Page 79 to Page 84 

Page 82 

! 11 than maybe ha 

:?I 

.-. MR EMVICK: Any questions you have on that area? 

MR. WISENBERG: 

Ii j until the end. 

I m Just going to save all mine 

:jl THE WITNESS: 

16 1 says that - 

I know - I can tell by the way he 

!73 MR. EMMICK: All right. 

19’ .~. BY MR EMMICK: 

[91 Q 

A 

Wt?o is Walter Kaye? 

Wa%er Kaye is a businessman from New York. He’s a 

ii y jwonderful, delightil man. Has he been in here? I don’t 

[ 12 1 recall if he has. 

I;:; Q 

A 

We can’t say. 

[:5] has, it’s 

All rght. Well, I should know. You know. if he 

116 1 delightfu ? 

robably been in and out of the pa 

VP” 

r. but he’s a 

man, a bclsinessman from New 01%. 

117: Q What is your relationship with Walter Kaye? 

[lBl A 

[191 0 

Sort of acquaintances. 

Does he call you to say hello? 

[201 A Not usually. 

[211 Q 

A 

Does he call you to get a hold of the President? 

[??I No. not that I can recall. 

1231 Q Is he regarded as close to President Clinton? 

[I41 

1251 

A Oh. I don’t know. By whom? 

Q By President Clinton. 

Ill 

Page 83 

A The President thinks evervone is close to him 

i2jYes. 

(31 Q 

I 4 I on the ohone? 

All right. Have you ever spoken with Walter Kaye 

isj ’ A I think so. 

[61 Q All right. I have some questions that I’d like to 

[71ask about a time when Monica did apparently visit with the 

[B 1 President and it was a ve short visit and it was at about 

[ 91 the time when President F edillo was in town. So I’m going to 

[ 1 o I ask you first do you remember when President Zedillo was in 

[Illtown? 

[I21 A No. 

Cl31 Q No? All right. Do you remember Monica coming by 

[I 4 1 the White House and havtng a very short meeting with the 

i j__, I T I President? --.-- 

A 

::76jaccounts of this and 

No. Y~~;;;;i~#i~ z lygyniJ;;read these 

[ IS ! you’re asking me - I do not re’member if Zedillo came once or 

[ 191 ifhe came ten times to the White House. We’ve had some 

;201 

P 

eople like Kin 

~2: 1 here probably a 

Hussein who was in town yesterday who’s been 

5 or 20 times. 

Q 

I::l timeframe. 

I’m talking about the October-November of ‘97 

[?41 A I don’t recall Zedillo. In ‘97? October of ‘97? 

[251 Q So you don’t have any recollection of that at all? 

Page 84 

[II A No. 

[‘i Q Do you have any recollection of Monica being 

I 3 1 brought in to the President’s study area for a time? 

[41 A No. I mean, if you have -well, I have no 

[ 5 I recollection of that. And then when you started that, you 

I 6 1 sounded like that was a given and, I mean, do you have 

! 7 1 confirmation that mat occurred? 

LB1 Q Well. rather than my answering your questions about 

[ 91 how much evidence we ma or ma not have - 

[lOI A You didn’t fai for it, luh? 

A No. I am unaware of a gift that President received 

i:iiduring this October or so of ‘97. 

[I91 Q Yes October-November. 

1201 

1211 

Aa lFo_a White House paperweight? 

[221 A Oh. what did you say? 

[231 0 

124 I House. 

An antique paperweight that depicted the White 

[251 A Oh. okay. No, I’m not aware of that. 
By 

1406 

Nancy Hemreich, 6/16/98 

Page 65 

0 

I. frogs? 

All right. Does the President have a collection of 

A Mm-hmm. He does have a collection of froas. 

Page 88 

: :. know beyond the realm of possibilities that you sa 

: I : somethin 

r :. but I don a? 

here or there about it or just the genera Y matter, 

recall anything specific or anythrng that would 

1;. reailY have any kind of impact or affect on thus case. 

[5. . 0 . I’m gorng to ask the same question about recent 

: c -drscussrons. anythin 

.-- A I don SP 

wrth senior staff like Bruce Lindsey? 

recall. But. aaain. I think vou have - 

L. Q Tell us about that. 

A 

;: He 

Well, we even go to laces like The Nature Company. 

-‘the 9w 

ives them away sometimes to P rttle children who come to 

hite House, too. And so he has a few frogs. And I 

5 ‘think Mrs. Clmton collects them, too. ) Q 

. . A 

And where does he keep the frog collection? 

I I : littler ones. 

Well, he has some that are on his desk, some of the 

‘1: ,especiall 

Usually, it’s - it’s cute when children 

come to the radio address, they’re always sort of 

-. them all’t!re ‘little froqs. xnd if he has an extra one or 

::,taken wit tt so he alwa s takes them up there and shows 

_? 

1: : two, then he gives tfiem away. 

; Q All right. Let me ask just a few more questions 

I I : and then we’ll let Sol pile on. 

ou had mentioned that on a couple of 

requests to search for documents and 

.:::things. 

.--, A Mm-hmm. 

.-3‘ .- Q I believe you said one time Mr. Kendall had asked 

.:: : ou to look for a couple of books and possibly Mr. Bennett 

:I: 1 tad asked you to look for things related to Kathleen Wrlley, 

i 3 .because there’s just this sort of constant. you know. - 

: 3: thmgs are constantly in the newspa er that it wouldn’t be 

[ 13 I out of the realm of possibility that I R ad 

[ :: ; discussion with Bruce, but nothin 

a general 

s 

; :?.agarn. that I think that you all wou Qi d 

ecific and nothin 

e - there would %* e a 

[ 13 : speutic interest. 

[i; : You mi 

[ : 5; going to the gran 1, 

ht sax, well, I may say to Bruce, ‘VVe,ll, I’m 

[;s:and when - 

jury. I mean, Bruce IS a friend of mane 

espectally .on foreign.tripsrs the-only time I 

[: T! travel. but we spend a lot of time together. And just In 

[I 8 : eneral conversation, it’s hard to have a conversation in 

[I ST +i IS town and not have ou know, some - discuss that in 

[~o:some four or fashion. -2 o - 

[‘I: 0 What about with Mr. Kendall or his staff7 

122’ 

[23jeve 

A I don’t think so, but I do talk to David Kendall 

r 

once in a while or Niwle Seligman. And I don’t 

[ 24 1 reca I that I’ve had any kind of specific conversations 

r25jwith them. 

:: ! but you weren’t sure whether it was him asking your coming up 

Page 86 

-1 .with it on your own. 

:?j -A Mm-hmm. 

Q My question is have you received any new requests 

f: i since the time of your last grand jury testimony to search 

: 6 ‘far documents or to search for things? 

.-, A Oh. lord. I’m sure we have. I mean - but I aet 

13 j most of them from the counsel’s office. Are you asking me- 

: 3: from the co-unsel’s office or - r____ _..L--.L_ __..___I*_ _z.__ __ L__ 

11:; rrom eirner me counsel 5 once or room - 

. . 

.--. A” Mr. Bennett? 

Q Mr. Kendall or Mr. Bennett. But since that 

: I_j : time, have you been asked to search for documents or for 

::::things? 

__ A I have from the counsel’s office. es. 

.I?. 0 

: - : matter? 

All right. In connection with the Monica Lewinsky 

_. 

-: A I don’t remember. Probably. And I say it fli 

: 3: but honestly, I bet we have a document re 

_. x 

uest - this mig I? t

- .be en exaggeration. but I know in the last t ree weeks that 

.I : : we’ve probably had three of them. 

^^ One of them was on - most of them - they’re 

‘z : orobablv for the House or the Senate. It seems like one was 

fi j on Bernard Schwartz and one was on something related to 

IJ j Indians or Native Americans. 

[l: Q 

Page 89 

With Mr. Bennett or his staff? 

A I don’t believe so. I’ve talked to Mr. Bennett in 

Ii j the last, you know several weeks month or so, but I don’t 

[ .I 1 even remember what it was about: 

! 2 i knowled 

Q We’ve asked you before whether or not to your 

FI 

e you were a member of a joint defense agreement or 

[ 7 1 some ot er sort of information sharing agreement and what you 

; 9 1 said was to your knowledge not. 

t9: 

1101 $ Mm-hmm. I ._____I____1 X.L___ L__ L___ __.. _L____ :_ IL_. 

I wonoereo IT mere nas oeen any mange in rrwr 

r 1: ; status. 

i:?j A No. 

[I31 MR. EMMICK: 

[ 1~ 1 questions to an end. 

Then in general, that brings my 

MR. WISENBERG: Why don’t we take with your 

i : 2; permission a brief - ask the witness to step outside - 

[I’: THE WITNESS: Oka 

[:3: MR. WISENBERG: 

[19:minutes. 

We’ll wme get you in a few 

i’i 

[?li 

i22“ 

THf WITNESS: Okgy. 

dness excused. Wetness recalled.) 

R WISENBERG: Let the record reflect the witness 

I 3 3: has reentered the arand iutv room 

1’4’ 

L-5: 

And Madam Fore 

THE FOREPERS&: 

rson do we have a quorum? 

Yes. we certainly do. 

Page 87 

I mean, I’d have to go throu h and fi 

f : know, what are the last, but we ge 1. quite a ‘$ 

ure out, you 

ew of them and 

T. cn I Ann’t rnmnmhar if I*YP hsd nna ml~tad tn Mnnirs 

_ “” I “““. ._..11111”W. I.._ 11”” “..., ._.I._” .” . . ..#...- 

: Lewinsky or not, the matter. 

Q 

A 

Anythin 

Not that 9 

related to Kathleen Willey? 

;’ recall, but that doesn’t mean that we 

:: haven’t had one. You all mi ht be able to answer that better 

I : because if we got one, it pro % 

f;Counsel. 

ably came from the Independent 

-. Q Possibly. 

-. A Possibl 

-. 

-_ 0 Possib r y not as well. 

i: A Yes. Yes. 

4‘ Q An 

5 i you've been aske Jw 

ay. you have no recollection of any searches 

to make for Monica Lewinsky related items 

: : 6 i since you last spoke with us? 

A I A--I. _--- II ___al_:__ .I_ c:___ I I__. ___I._ .._, 

.- . I eon I recall anymmy. PI”. 31”Ge I last spune 

-:-:,with you. 

Q 

!:i Lewinsky or Kathleen Willey with the President 

Any more recent discussions regarding Monica 

A I don’t think so. And that’s one of those I’d have 

.if:to think about, you know, just - because thin 

::I : recall an 

Y 

specific conversation I’ve had with 9 

s - I don’t 

he President 

-4 1 or, frank y. with anybody else, but it’s in the papers, 

: f 5 : obvtously, day in and day out, and it wouldn t be - you 

Page 90 

:3i 

:5: 

ii‘ 

MR. WISENBERG: Are there any unauthorized persons 

Nn thram arm nnrm 

Ms. Hernreich you are st~~u~$;o’a~h:‘-“-’ 

THE WITNESS: Okay. 

BY MR. WISENBERG: 

i7j 0 Ms. Hernreich, I’m goin to ask you some questions, 

[ ~~sorrte of which are mine, some of whrc ,I! 

19;from the grand ‘urors. 

are the grand jurors’, 

ii?' 

. : 

A bka 

Q AndYlet me just preface it by saying that you’re 

iii i not required to be 100 percent certain before you give 

I :j: an answer. What we’re interested in is your best 

f 14 : recollection. 

i i 2 i visited the 

You said ou’re not even aware now that Monica 

Presiden r ~~ _ IL_ >.-t._ L,_____ with any regularity afler she lefl “___ __: A I__& ._ ________ .a ___ _I [ L7 : u1e YVrllIe l-louse. T,OU saw mat I” respunsr ,” “llc: “1 

113 :Mr. Emmick’s questtons. 

::5: Let me ask you, has he denied this to you? Has 

[33: the President denied to ou that Monica visited with some 

~2: : regularity after she left t X e White House? Was transferred, 

[2: : in other words. 

l-731 A To my recollection. I’ve never had that 

[ 14 : conversation with the President. 

[25: Q What has he told you about his relationship, if 

_ _. _ .~_~~ 

Page 85 to Page 90 
1407 

BSA Nancy Hemreich, 6/16/98 XMAX/lUW 

Page 91 

[ : 1 any, with Monica Lewmsk ? 

1,‘: A I don’t reca Y Ithat I’ve had that conversation. 

[ 3 1 Ithink early on, at one pomt. we talked about the fact that 

[ 11 Walter Kaye - at some pomt. we talked about the fact that 

[ 5 1 Waiter Kaye - that she Interned because Walter Ka 

[ 6 1 she was a friend of Walter Kaye’s, sqmething to tha r 

e had - 

eff+t, 

[7)and that at some point. as I satd eariter, he said,something 

[ 8 1 to the effect that ’ I didn’t do this. They don’t belleve me. 

[ 91 Ididn’t do this ” But I didn’t - I didn’t press him on 

1 o 1 what he was talking about specifically. 

:I?] 0 Okay. At some point after the scandal broke, he 

i 1: 1 told you, “l_dld$ dq this.” .ls that correct? 

13: A Mm-nmm. yes. 

.14: 

.15; 

2 2~. didn’t identify what “this” was? 

0 Okay. And he didn’t tell you anything other than 

::;;“I didn’t do this?” 

:18; A Not in that particular conversation. I don’t 

19 1 recall having other ones with him about this, but that - 

,zo! that’s all I remember of that. “I didn’t do this.” You 

,211 know. “Thev don’t believe me. I didn’t do this.” And I 

iz2 jdidn’t’press-him on it. 

Q Oka 

!iil biggest, scandals o Y. 

Certainly one of the biggest, if not the 

i:slfalr statement? 

ha entire political career. Is that a 

Page 94 

- A That’s all right. 

.-. Q And would that have been a special concern about 

j i Monica since - because of her clutch reputation? 

. A Well, I don’t think specifically Monica because she 

;. had a clutch reputation. It would have been a concern. 

; Q Okay. You wouldn’t have been concerned about 

i’ Monica any more th,an anybody else if you found they were 

?. regularly yebn with the President? 

._. 

: ig’mean, if it’s 

d. ell aart of that - didn’t vou ROY - VI=< ! 

son-&i& I didn’t know anb’$oj< sudd& I 

::I-found out somebody I! ad been coming in a lot? Yes, no matter 

::z:who it was, I would want to know. It would wncem me. 

.--. I wouid at ieast ask ou know, whether it was a 

:: f ‘man or, you know. anEr. dhy would somebody be coming In a 

f :; lot to meet wtth him? a are the issues? What’s going on 

::iihere? Is there something I need to know about, something I 

: :T need to be concerned about or work on? 

i:9: Q 

jiz;clutch - 

And yet here was somebody who had a reputation as a 

_-i_ A Well - 

r-3. .-A_ - at least among some people. 

‘-2. 

.--. 2 Yes. 

Q And that mi !:: jshe was transferred out of w ht have had somethin to do with why 

e White House. Wou B dn’t that 

i’5: have even heightened your concern? 

Page 92 

ill A Yes. But immediately, as 

; 2 IYOU know, somewhat blown out of prop0 k ion and that’s my 

ou know, this was - 

[ 3 j issessment of it. And so - I mea6 to sit down and have 2 

[ 4 ! purposeful conversation with him is just not something either 

[ 5 1 one of us would do. 

Q Oka 

I: j just saying that he $ 

So he never gave you any - other than 

rdn’t do this. he never 

[8 !explanation, for instance, of why he might R 

ave you an 

ave met with 

[ 91 Ms. Lewinsky several times? 

101 A We’ve never discussed it that I remember. 

Q Since Monica was transferred at least partially 

:; i because she had a reputation as a clutch, why wouldn’t you 

13 1 be concerned if you found out she was regularly visiting 

14 1 the President when you werenY there? 

: 2 ] we said. 

A Well number one I’m not sure that that’s what 

It was likd whether she’was visiting the White 

17 1 House or visiting Betty, wasn’t it? Wasn’t that what you 

I?! asked me? 

15; 0 Well, let’s do - 

711 -_1 A And I don’t know that she was visiting the 

2:: President, to this day. 

__ 3”. i Q Okay. Well, let me ask - 

23’ 

241 

A 

0 

I haven’t had anybody confirm that to me. 

All right. Well, let’s assume that she was. Let’s 

2 5 ! start with the President - let’s start with - let’s do the 

Page 95 

111 A Well, when we had that conversation, I’m not sure I 

[r-had - clutch mav be a little bit of a strona word. vou know, 

13 j Evel 

Y 

n 

r4:and 

Liebemdn may have had some &ncerris’ about her, but - 

had seen her, you know, walk b when we were over In 

[s;the map room a couple of times, but t K 

: 6 :as a clutch, that’s 

at she had a reputation 

our characterization and not mine. And 

~7 1 I’m not sure I had 

i;:th;tp$ople sat and talked a 

, that she was .a clutch. ?r 

out her and said this girls a 

. I 

::oi Q Okay. Were you even aware of her reputation as a 

: i 11 dutch? 

;;;;like her, <o0 

- - : 

Well, let me rephrase my questton. 

..~. A Well, I don’t know. I mean, ou’re askin me to 

i;3:‘udge and I don’t know that I thou 

-1 

ht that o ! Monica or Wat 

j:si would have thought any more o P It. If anvbodv was meetina 

izalwith the President-on a regular basis and 1 didr?t know abouf 

! 2 1: it, I would want to know about it. 

:zy:they were meeting with him. 

I would want to know why 

!23: Q And I uess my uestion to you is then aside from 

i 24 : what you knew about 9, er reputa 1. Ion. was there anything 

:zs:that you knew or heard or thought at Monica Lewinsky in 

Page 93 

[i 1 President and then Betty. 

If you found out that Monica was re 

Iz j the President when you weren’t there, would t a IS be somet 

ularly visitin 

1. 

[ 4 1 that would have concerned you, given everything you knew 

ing 

;;I about Ms. Lewinsky? 

A Wel, it would have concerned me enough to ask 

I 7 1 somebodv about it. either the President or Bettv. at the 

; 9; time. vouknow. if i had known about it But I tr? not to 

[3jprejudge. 

0 

i :y i to ask somebodv about it? 

Okay. And why would that have concerned you enol lgh 

well, I think that - well, concerned or I would 

[2’! Q Would that be - 

A If they’re coming in that much, if they were coming 

1;: 1 in to see the President. Yes. 

[25i Q Sorry to cut you off. 

Page 91 to Page 96 

Page 96 

1: :particular that would have even heightened your concern? 

!?I What it was that you heard or knew that would 

13: have heightened your concern even above the wncem you’re 

r 4 : tellina us YOU would have felt if vou found this out about 

ijjanyofie? . 

[6: A Well, to be honest, I would be more concerned about 

! 7 ; a woman because I 

: 3 : appearance doesn’t 

- you know, the 

I would a man and so 

tg:because she’s a woman, would have a little more wncem 

r;;:about it. 

il:; Q Okay. Other than the fact that she was a female. 

r I ~1 the fact that she was a female who was Monica Lewinskv? 

! i3! Would that have heightened your concern at all? 

1‘4‘ A Honest1 , Sol, I don’t think so. I don’t think 

;:5ithat she had that negafie - I think what you’re gettin at, 

; I6 iwhether she had tha negative a reputation in the WI e House 

!17jor - 

f i z ltime 

Q Just is there anything about what you knew at that 

what vou knew before the sanda! broke but &r she 

.I 41 A Probably a little bit, but not, you know, an 

i?s;excessive amount. And, you know, you might put everybody in 

OlCStarr 
1408 

BSA Nancy Hemreich, 6116198 XMAX(17117) 

Page 97 

: I! some sort of category where, you know, you have a baseline 

I: ! here and, you know, you mi 

~3 J might be a little bd over the 

ht start ratcheting it up, she 

% 

[ 4 : I mean, so you’re askin 

asellne, but not way up here. 

2 

me to judge something that - what I 

I K I cav mav _+m~fld wgr+p !. ,z” t&m! ! :pz!!v fd!. yes, I minht 

; 6 1 hzi’afittle more concern about it as Monica. 

~7 Iwouldn’t be - it wouldn’t be outrageous. 

I pr%&& 

Q You mentioned that ou would sometimes go over to 

1 Ei the White House or be at the White Ii ouse to be there when 

[ 10 1 personal friends of the President came in. I believe that 

[ 1; 1 you testified to that effect. 

ou remember an 

i 17 j only time thiy &n come in. 

[IS! 0 You don’t remember any particular names right now? 

,191 A I don’t. but I could - if vou needed me to. I 

iioicould come up with ttiem. It might take me 24 hours or.1 

(21 !might have to go back and try to reconstruct things, atthough 

(~2 J I don’t know that I could reconstruct it, but if I thought - 

123 1 I could go back and ask Rebecca or somebody else to 

~24 1 remember. 

help me 

!251 Q Okay. What do you recall about - do you recall 

Page 98 

L 11 anything about the da 

[;jon the witness list? hx. 

after Monica Lewinsky’s name appeared 

r Emmick asked you a question kind of 

[ 3 1 on this topic, but what do you personally recall, if 

(4 1 anything, or what were 

[ 5 1 happened on the day a ty 

ou told about events that might have 

[ 6 1 list in the Jones case? 

er her name appeared on the witness 

171 A I am unaware. that I recall. of beina - I have no 

i 8 j recollection of being aware ai that time, which wa’s like 

~91December 4th, did you say? Something like that? When this 

-:o!witness - 

111 MR. EMMICK: 

1’: -l-UC ,fi1(TLIlz’PP. 

nr h-‘-- 

“...^*^ a.“. I....- ..^_^ 

I; ; was on 

I nc ““I I l”L33. 

Th+$;h. 

“I “cllly avvatc: LIIaL 1111 IldllE 

an witness list at that time. 

13; &Y MR. WISENBERG: 

151 Q 

16 1 the Monica sto 

Okay. Did you hear any confirmatory rumors after 

A 

broke from anybody? 

171 %hat do you mean by that? 

:iiSomebod sayin somet in about ‘Well 

2 0 1 to me.” 

dT S.;mebo;~.s~ing s~thif,~~~~~~~~~~~p~. 

ings II e that “T at con arms something that I 

2i ~saw.” Anything like that among your acquaintances or friends 

? 7 1 whn wnrkmi in thn White l-ina nce nr haA wnrkd in tha \Nhita 

.._...__ .., . ..” . . . ...” ..“““., “. ..“_ .._..._” *.. . .._ . . . . . . _ 

s; j %;se or knew the President or knew you. 

241 A Specifically what are you talkin 

25 :‘That’s not a surprise to me” that what was? 9 

h;F$z _Like 

Page 99 

il! Q This idea that she had a relationship, an alleged 

[ 2 1 physical relationshi , with the President. 

i31 A 

14: 2 

Oh, Pdidn’t hear an bod say anythin? like that. 

Okay. You unders r and Y he question. 

[:I Wall vnon’rn n&inn ma whothnr I PVOI haawl nnvkrvlv .._I., ,“” I_ ““,\“‘J .*a” . ..*_.n._. . y-w’ .._...I ‘.*,“.v.d, 

i 6 1 say anyth;ig like - after there was these allegattons of a 

[ 7; relationship with the President, did anybody say, ‘Well, that 

[ 9 : doesn’t su rise me?” 

[5i 3 Right. Or “So and so saw them somewhere.” 

[lOI A No. 

!111 Q like that? 

!121 

‘11, 

fi 

Anythin 

No. I di 3, n t hear anythin’ 

Okav You mentloned tl 

g like that. 

-.._ __ .______._..__ iat you recalled in 

i ;i i connection-with Kathleen Willey - 

[ 15 1 recollection of a conversation with & 

ou had a vague 

ruce Lindsey, correct me 

I 16 1 if I’ve got it wrona. concernina whether he returned a call 

! : 7 i from Unda Trippr 

[181. 4 Well, somehow in the back of my mind. I have this 

[ 191 idea that Ll?da Tnpp tried to call him at some oint. 

[2olwhere I ot it. I don t know. And whether I JUS P 

Now. 

[21]or if I a c? 

made it up 

ually. you know, recall this and whether I had a 

: 22 1 conversation wdh Bruce or not about it, I don’t know. 

1231 I think I had a conversation with Bruce to the 

:24 jeffed that did Linda Tripp ever try to call you or did she 

~2 5 I ever try to call you and you not returned her phone call or. 

OlCStarr 

Page 100 

’ 

r 

ou know somethin 

? 

to that effect but I can’t be certain 

ji have thi; Idea that lnda Trioo trted to call him and I 

ii : think I had a conversation with’ him about that. 

. . !Y. Q Do you recall whether or not he was cnticzed for 

c innt rcatllrninn a Nancy bon nr PSII frnm I inrig Trinn? 

:$‘ 

._ .._. ._._ . . . . ..= _g,-J&;;jr _. -.. .._... _..._” .*‘rr. 

i_: Q Anybody. 

[5 A Not that I’m aware of. 

[4j Q Do you - how many conversations have ou had with 

; 12: Bruce Lindsey about the Monica Lewlnsky matter since t b e 

1 I: ; story broke? 

[iI‘ A I don’t know. You know, I don’t know that I had 

[:3‘any just sit down, “Okay, Bruce, let’s talk about this and 

1:; lot and scheme.” I mean, I don’t have conversations with 

1::: g ruce like that. Whether you have a general conversation 

[I 6: about what’s in the paper or I’m going to the grand jury 

[:7:or - 

[l?: Q Anything. Let’s just be broad. 

[19: A I don’t know. 

c20: Q What can you tell us - give us a ballpark idea of 

(2 1: how many times you’ve discussed Monica Lewinsky or the Monica 

[? 2 ; Lewinsky matter with Bruce since the story broke. 

[23: A Hmm. 

Q And when I sa 

i::;Washington Post on January 

Page 101 

[I! A Well and ou’re talkin just in general? If I had 

12 1 any conversations like -t?id you read?he newspaper today?” 

13: Q Yes. How man ? 

[4: A Probably 10 or 3 0, maybe more. Again, I think I 

15: have more conversations and I see Bruce, which is on the 

[ 6: road, and Since that time, I uess we’ve ‘ust been to - I’m 

[~:trying to think, to Chile and ? .o Europe, I, d on’t know if 

[B ; there s another Euro 

[ 9; road and.you’re rea dpe 

an tnp. but certainly we’re on the 

ing the,paper, you might pass, 

[ I o ! we get clips on the road, “Did you see this artele? 

ou know, 

K s an 

[I;: interesting article.” Or somethmg like that. P^ ___..^ -^*:^-^ ^- -___ ,:1__1__ L_ __-.._ 1x__ *1_1 ii?. 3” C;O~IV~IS~LIVIID dre rrro~c: llna~y IO DCCU~ me mar 

L rl>-when -. we’re around each other, you know, 18 hours a day..so 

114 : man 

[ 15 1 or ta Y 

days in a row, than on a regular basis. I don’t see him 

k to him daily In the White House. 

116: Q About how man conversations do you recall with him 

[ 17: that were not based on press s r 

[I 3 1 Again, after the story broke. 

ones about Ms. Lewinsky? 

[?9: A Not based on a press story? Well, maybe one or 

[:n:two. I’m not even sure that’s an accurate number. It may be 

i2: :five, it may,b” zero. You know. ._I_). I%, “n,, rrrrsll tha mntant nf +hncn mn\rarr=tinnc a+ 

;_;jall? = 

WV ,“” 1”_1. .I,.. W.l.lll. “I LII”SS ““II..zl.3~&l”ll~ _L 

[:a: A No. About the whole Monica Lewinsky matter? 

[25: Q No, the more narrow category, the zero to five. 

Page 102 

[I: A Thezero- 

[2: Q Obvious1 

r 

if you had zero, there’s nothing to 

[ 3: recall, but do you recall he substance of any wnversatlon 

[ 4: with Bruce about Monica that was not press related or not 

r c. rrrlstarl +n enma c+nru in th- nrmcc *h-t h-n-nnrl d+sr tha IJ,Ib.a.u” .” .,“#I,., e.v,, 1.1 l .1 y.c.Ts ,I.%., Iw+.yr,,r” w,,r, ,,,r 

[ 6: scandal broke? 

[‘: A I don’t recall any right off the top of my head. 

13: Q Do you recall any conversations - 

19: A 

[ 1 c 1 recall one. 

But give me enough time and I might be able to 

[ll: 0 All ht. Do you recall any conversations with 

rl2’Bruce Lindsey abo ?I? 

i13ion January 21st? 

Monica Lewinskv before the scandal broke 

114: A No. I don’t recall any beforehand. 

[15: Q You mentioned that after Ms. Wllley called you to 

[ 16: tell you abqut her contact by the press that you think you 

[ I 7 : mentioned: tohh;;;;pent. 

[l?: 

Q And ou think he might have told you to talk to 

I:z:Bruce Lindsey abo$it. 

[:I: A Well, he may have or he may have just said he would 

r22:talk to Bruce about it. I don’t know. 

c23: Q And I think you said Ms. Wtlley mi 

? 

ht have asked 

[ 24 : you to talk to the President or you might have jus done it 

; 2 5 : on your own. Is that correct? 

Page 97 to Page 102 
1409 

Nancv Hemreich. 6/16/98 XMAxH(V18, 

Page 103 

1.. A 

:: 1 cnnvnrsntinn and I don’t recal dlscusssna ths todav but 

_Yes._! donT_a?a@, recall a speufic 

;;jw&m~yhave dtscusted it at another tim’e, but. es, she may 

I 4 1 have asked me to do that or she just - maybe x at was my 

i 5 i assumption. 

i6i is one of the reasons you toid the Presideni aboui 

:7 1 the VWley %I because ou sus 

‘f R. 

ected that he mght have had 

19 1 a relationsjip w$. her o some md? 

.-1 

.=1 

::01 ‘6 ‘l%i you ever talk to - 

..-I I’m on the last age. 

.I_), THE WlTNES8 

::;;Evervone’s hunarv. 

You all want to go to lunch 

.:4; 

-151 

pupi) 

IS NBERG: I need to confer with Mr. Emmick. 

:i61 

ICK: 

Q All right. Well, let’s confine it to the last - 

iglifrorn - let’s confine rt to December, the beginning of 

Page 104 

[ 11 December until January 21st. Did you ever talk to Vernon 

;Z; Jordan about an affidavit or statement? 

[31 A Not that I recall. 

Q All right. Did you ever see the President alone in 

i li the Oval Office complex with Monica Lewinsky? And let me 

; 6 1 define the Oval Office corn lex for purposes of this question 

[ 7 1 because we might have as R ed a similar quesbon early on when 

[8]yOU were here. 

I would include that to be the dining room, the 

x i,‘i Oval Ofhce dining room, the study, the hallway that leads to 

1111 the study and the dinin 

# 

room, the Oval Office itself 

# 

our 

: 12 ~office or Ms. Cunie’s o ice, or the bathroom that’s o of 

;:3lthat halhva& 

1141 

::31 President ; 

td you ever see Monica Lewinsky alone with the 

the Oval Office corn lex as I ve defined tt? 

Might I say somet I? mg about the way that uestion’s 

;:; 1 asked? Because if I saw them alone, then they weren’t a 9 one 

,: 19 j because I gas $tt;hem, so - 

:101 

:I?01 x fi<&swer to that would be no. 

;I?11 Q 

: 211 been alone? 

Did you come upon them when they apparently had 

.~.1 

t:; i you this 

0 

at 

Any kind of event - I think we might have asked 

an earlier time, but sometimes an event hap 

[ 18 1 and something that hap 

I I slthe time think was siani can! becomes sianificant. this is a 

i 26 i s&ri& 

_ ,P 

ened in the past that you didn #pens at 

izllnot it d

uestion,, but do you recall any kina of - whether or 

to Monica’s transfer, any kind of thin 

~22 Ifr_om,any,body about an_unus,ua!_event of any ii. 

you heard 

rnd involving 

:231 A No. 

0 All right. Did anyone ever tell you that they had 

~23 ]Ms. Lewtnsky and tne President! 

iz z i seen them alone or come upon them when they were alone? 

A No. I have not heard of anything or anybody talk 

I:llabout it. I guess that’s what you’re asking me. 

Page 106 

[ ; j comrng out. 

/7) A .-I I don’t recall any time that I thought they had 

[ 3: been alone like that. 

0 Now. let’s take the converse. Did you ever see the 

1 !i both of them heading toward a room where you thought that 

[ 6 1 they were going io be aione or one or the otner headmg 

[7jtoward a room where the other one was waiting? 

[El A Not that I recall. 

[9i Q Oka Did you ever hear about - you say you never 

;;;;;rtiEn!hem- 8 fy Id ou ever hear about an event of any krnd 

onrca s trans er out of the White House that caused 

[ 12 1or might have led to - been one of the things leading to the 

[ I 3 1 transfer out of the White House? 

A I don’t think so. I’ve not thou ht of that 

I :l i question in that way before, so - but I don’t 9 hink so. 

Have I ever heard of an event which may have 

I :76;caused her to be transferred out? Is that what you re 

[ I 8 1 asking me? 

Q Yes. Either an event that somebod 

I:zior something, even if it’s not an event, something t b 

witnessed 

at 

[ 2 11 somebody saw that basically was told to somebody and that 

[~]was one o;theh:asons that she was transferred. 

[231 

Q Okay. Has the policy about gifts tightened 

If:iup at all about how gifts are received and logged in, 

.-- 

Page 107 

htened up at all, since the Monica story became 

A I don’t think so. 

Q You said that you didn’t -were you about to say 

i 5 j something? 

A Well, I was just thinking I got a call yesterday 

j76jfrom somebody who wanted to know why she wasn’t thanked for 

[ 8 1 her gift, so I thought, well, no, it hasn’t because I’m still 

[ 9 I getting - 

llnl BY MR. EMMICK: L--1 

[Ill Q It wasn’t Monica, I take it. 

1121 A No, it wasn’t Monica. So I thought, well, we’re 

[ 13 1 still not doing a good job of getting these gifts fogged 

[:4ldown. - _ 

1151 BY MR. WISENBERG: 

Page 105 

:I! A No. Not that I recall. 

:21 0 Okay. I had started telling you - one day you 

:3 ~started answerina a auestion I asked. it was near the end of 

i 4 j the day, certain people were restless; kind of like they are 

: 5 1 now, and I had asked you whether or not you saw Monica 

~61 heading toward a room where you thou 

l7 1 be and you answered yes and you 9. 

ht the President might 

men roned pizza. I think you 

: 9 1 mentioneddhe 

euza Incident. 

n uh That isn’t what you asked me. What you 

: I,‘; asked me was did I ever see them coming out of somewhere I 

: II 1 thought the ma have been alone. 

:12] d dkav. 

::31 I% I think that was the wa the question was phrased. 

114; 0 I stand corrected. An d 

: ~5 1 incident. 

you mentioned the pizza 

::61 A Yes. 

Q Lets stay with that formulation. Did you see them 

[iii coming out or any one of them coming out of an area where you 

: : 9 1 thought they had been? Is there any Incident other than the 

: 3 o 1 pizza incident? 

‘7’11 A Not that I can recall. And, obvious1 

‘:I 1 some time to think about it. but I’ve not been able r* o recall 

I’ve had 

i23jany time. 

0 Okay. And that’s either the both of them coming 

iiziout of where you thought they had been or either one of them 

Page 108 

[II 0 Right. 

A 

iS i before, was I 

How is that different than what you asked me 

aware of it before? 

Q 

personall 

i l i her transfer. 

Before K was something that might have prompted 

161 A Yes. 

MR. WISENBERG: 

ti 1 questions I have. 

All right. I think that’s all the 

[VI, 

rlolturors? 

Are there any other questions from the grand 

OR 

[::icall on the&1YPli& 

When Vernon Jordan called you, would he 

TRBWITNESS: That’s why I was kind of surprised 

i : z i that they had only found calls in November or whatever. 

[ I 5 1 Idon’t know. 

[I61 I actually have four lines, one that no one uses, 

[ 17 1 it’s just an incoming call, but I think there’s a number 

[ 18 j aSSl ned to it or an extra 

[ 19lAnd 9 

hone 

hen D, which is t 1 

is what it is for my office. 

e one my dau hter ‘ust has and 

; ; ; ; ;;t; $~$g=$$v~~l;;;~it in&$ t;gf!;;; I 

[231on my desk and Rebecca’s desk simultaneously. 

t:: icall 

So I have a feelin 

$ 

that Vernon when he would have 

d would have called on 

rrsi(llfi 

he_ number rather than the 

number. But, you know, who knows? He may have just 
1410 

BSA 

Page 109 

Nancy Hemreich, 6116198 XMAX(l9/19) 

: had -that’s a semi-private number and a lot of people have 

: d that - you know - 

-. A JUROR: Which one is semi- rivate? 

THE WITNESS: The_ % he ma have had 

;-that number to call me directly I may have given d 4o 

r hrm. 

A JUROR: If he did dial the 

::on Rebecca Cameron’s desk, how woul d 

nd it would ring 

3 -was on the hone? 

she let you know that he 

.-- TEE WITNESS: She would intercom me. We have an 

.::. intercom system between our offices. And that’s why - well, 

: 1: : I know Rebecca’s or Kris Engskov’s intercom number, but I 

: 11 .don’t know therr re ular phone numbers somettmes. 

. _% A JURO w : Would she then transfer the call to 

: :. another line? 

_. TLIC \IIRTkrCCC. V-r rka rrr*#lrl ,*a” ..-rr‘..%rr i, .-L. I I IL ..I I I.LUU_ I =a, ail= bu”I” LIIGII LIIIIJIG, I,. She 

: : - : could transfer it to - I don’t know how she does it, whether 

: I 5. she transfers it to the aor she can intercom and transfer 

: : ?-it. I don’t know how she 

._.: A JUROR: 

oes rt precrsely. 

It just seemed unusual to me that the 

:f i -line would be your published number and not have it on 

:rr:your desk. 

.-- THE WITNESS: Yes. It’s just because I can’t 

1:: :possibly answer all those calls and it’s published for 

;rz:everyone in the White House and it’s hard to conceive of the 

Page 110 

: : : number of calls that I get asking me - you know, the 

:I : President’s friends or staff members or others who want to 

: z.know somethin 

3, 

from the President a day. So poor Rebecca has 

: ;: to answer it or t e Intern. 

= .for them. 

It gets a little overwhelming 

i ; : 

._. z%z&?z%~u 

Q Did you ever see a book or a gift that anybody gave 

i:the Pre+itient that vml fmmd trmihlinnl) . _ _ . - - . . . _. , _ _ . _ _ _ . . _ _ _ . . = 

. A I don’t think so but let me think about that. 

:I; j We get some pretty unusual stuff. Troubling. I don’t 

rs;Jo. response.& 

R WISENB RG: 

:ff-for a few more minutes. 

I’m going to ask you to step out 

_^. 

--. THE WITNESS: Okay. 

.._ ..n_r.,.-.r__ . ,- --.-L. ~. 

--z. 

.--. MK. WlZatNe)tiTU: we mignr not need to have you back 

,I:-in. 

.^Z. 

--. THE WITNESS: Okay. 

Page 111 

. MR. WSENBERG: 

1: j your notes. 

I’ll also ask you not to destroy 

.-. THE WITNESS: I won’t. 

. . 

-. The witness was excused.) 

.;. bJ hereupon, at 1250 p.m., the taking of testimony 

: z f in the presence of a full quorum of the Grand Jury was 

.--concluded.) 

‘L- .*.** 

.-. : 

.--. ,.^. 

--, 

: 

.--. 

:::‘ 

.-- 

,. _. 

.-c. 

,._. 

.- 

.-:’ 

_--_ 

.. i- 

.--. .^.. 

.--. 

._. 

_--. 

,__. 

.--. 

‘-:’ 

.--. 

.^ 

.-- 

__: 

.--. 

OK-Starr Page 109 to Page 111 
1411 

I 
1412 
1413 

lmlu 39 1 llof$ 

lvlu.lu-I QLi- 1 uv.m-,, @mu, I”, L/X. 

Page: 

UH**zO Sf%xs D:zza:z COlfR~ 

F0OR 1lIz DISTI1C: cf ;oLu*I)II 1 PROCEEDINGS 

_______---------_l 2 whereupon, 

*Y RL: 3 REGINALD HIGHTOWER 

rz+AND .NnI PROCCEOXWCS : 4 was called as a witness and, having been first duly sworn by 

___r_--____-----_I 5 the Fomperson of the Grand Jury. was examined and testified 

Cr& Jury Roan “0. 2 6 as fob.vs: “c,iuC SULCI Di,tCICt to”rL 

*or UN rJ1,rri.S Of COI_I. 7 EXAMINATION 3rd ‘ eon*ritution, w.*. 

w~~hiDqcoa, D.C. 8 BY MR. SUSANIN: 

lut,til. .lu>), 2s. 1998 9 Q Good morning, sir. 

nlc rc,tiMny ot RTc*wALD “*RI-R “.I Lat=n in 10 A Good morning. 

LIILC pr.*.ne* 0t l t”ll quorrur 0t CIrad Jvry 97-s. Lmpn*l*d 11 Q Would you please state your full name and spell 

OJl DcCens.Q~ 5, 1497 cwcncinq 1c 9:39 .,zS. bcforr: 12 your last name for the record? 

rrrroznr S”sNl1Y A,,OCI.Z* In.l*pcndcnt c-1 13 A My name is Reginald Hightower. Rtg-i-n-a-la 

60111uID PAGE A,,oci‘r. Inb.~nd*nr coM9.1 14 Hightower, H-i-g-h-t-o-w-e-r. 

-‘I nnnE *ram 

otti.=* 0t In*.~n**n~ cDnrl.)Cl IS MR. SUSANIN: Mr. Hightower, we briefly met a 

1001 Pcnn,Y1”ml& A”ChUL, I.“. 

Sulrc 490 worm 

16 moment ago, but let me reintroduce myself while we’re on the 

“Irnlnqron. D.C. 2000, I7 record. And, incidentally, 1’11 ask the foreperson if there 

18 is a quorum. 

19 THE FOREPERSON: There is a quorum. 

20 MR. SUSANIN: And whether there are any 

21 unauthorized in the room? 

22 THE FOREPERSON: No, there arc no unauthorized 

23 people. 

24 MR. STJSANTN: Okay. Thank you, ma’am. 

25 

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CDH+EYTS 

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1 BY MR. SUSANIN: 

2 Q Sir, again, my name is Timothy Susanin. I’m an 

P*.GE 3 associate independent counsel. I want to let you know who 

4 else is in the room. 

3 5 Across from me is the court reporter. To my left 

6 is the foreperson of the grand jury. At the far end of the 

7 table are other members of the grand jury. And everyone 

8 sitting out in the chairs are also ladies and gentlemen of 

21 9 thegrandjury. 

10 A yes. 

II Q As you know, I’m going to be asking you some 

12 questions before the grand jury this morning; and I want to 

13 take a moment or two to let you know about sorrz rights and 

I4 obligations you have before this grand jury. Do you 

15 understand sir? 

16 A Yes, I do. 

17 Q Before we get started, I’m going to ask that you 

18 try to elevate your voice as loudly as possible, so the 

19 individuals in the back can hear you. 

20 A Okay. 

21 Q I know it’s going to be tough. At times, you might 

22 feel like you’re &outing at us. But we’re going to ask you 

23 to do that, so everyone can hear you loudly and clearly. 

24 Let me tell you, before we begin, you have the 

25 right to counsel, sir. vou don’t have the right to have an 

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1 attorney in the room here with you. but you do have the right 

2 to stop at any time and step outside and consult with your 

3 attorney. Do you understand that? 

4 A I understand that. 

5 Q And do you have an attorney here with you today? 

6 A I have a Secret Service, yes. I understand. 

7 Q Secret Service attorney? 

8 A Yes, sir. 

9 Q Do you have a personal attorney? 

0 A No. No. 

1 Q And who are the Secret Service attorneys you have 

2 here with you today? 

3 A Matt, I forget his last name, and Tom Doherty. 

4 Yes. 

5 Q You let us know if you want to stop and con%lt 

6 withthem. 

7 A Oh, absolutely. Absolutely,. 

8 Q I’m also going to ask that you make sure you wait 

9 until I’m finished speaking ‘til you answer a question, and 

0 I’m going to try to wait until you fmish your answer before 

1 Istanupagain,justsothecourtreportercantakeusdown 

2 easily. 

.3 A Yes. 

:4 Q You are under oath: do you understand that, sir? 

:5 A Yes, I do. 

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1 Q You have an obligation to tell the truth before 

2 this grand jury? 

3 A yes, I do. 

4 Q And you understand that you can’t mislead the grand 

5 juiy? 

6 A yes. 

7 Q And that indicatmg to the grand jury that you 

9 don’t recall something when you do would count as not tdlin~ 

9 the truth. Do you understand that, sir? 

3 A+Oh, yes, I do. 

1 Q You have a fifth Amendment right against self2 incrimination. In other words, if you feel that the truthful 

3 answer to a question I posed to you would tend to incrimin& 

4 YOU, you have the right not to answer that question. Do you 

5 understand that, sir? 

5 A Yes,Ido. 

7 Q I-&y, I want to a.& you to make sure, as you’ve 

B been doing, that you give a verbal response here before the 

9 ladies and gentlemen. In other words, you can’t nod your 

0 head or shake your head. You have to give us a “Yes” or 

1 “NO,” SO the court reporter CXI take you down. Do YOU 

2 understand that, sir? 

3 A Iunderstand that. 

4 Q All rig&. Let’s begin, sir. You’re a special 

5 agent with the Secret Service; is that correct? 

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1 A YesIam. 

2 Q Tell the ladies and gentlemen where you work within I 

3 the Secret Service. Agent Hi&tower. 

4 A I’m a&_& to the Presidential Protective 

5 Division and Cght now I’m on the counter-assault team. 

6 Q lbe counter-assault team? 

I A Ycs,Iam. 

8 Q I’m going to remind you again to try to keep your 

9 voice up. 

IO A okay. 

I MR. SUSANIN: I know it’s difficult, hut as much as 

2 possible. Ladies and gentlemen, let us know if you’re 

3 having problems hearing, okay? 

4 BY MR. SUSANI-N: 

5 p Is the detail that you’re assigned to known as the 

6 PPD? 

7 A Yes, it is. 

8 Q Tell the ladies and gentlemen how many years you’ve 

9 beenwithtbeSesrec.Service. 

‘0 A I’ve been in the Secret Servi& nine-and-a-half 

1 years, now. 

2 Q And when did you sfart with the PPD? 

!3 A I stafied wifh PPT) March of 1996. 

!4 Q And were you with the Uniformed Division before 

!5 then? 

PaSe, ‘I 

I A No, I was not. 

2 Q Where did you work before you were with the PPD? 

3 A Before 1 came to PPD, I was assigned to Chicago 

4 Field Office. 

5 Q What did you do there? 

6 A Investigate Secret .%-vice violations. 

7 Q HOW many years were you in the Chicago Field 

8 Office? 

9 A Seven years, approximately Seven prs. 

0 Q So you started -- 

1 A Yes. 

2 Q - with the Secfft Service in the cbicago Field 

3 Office? 

4 A Yes,Idid 

5 Q And mx you started with the PPD - I believe you 

6 said in March of ‘96; is that right? 

7 A -&at’s cormct. 

8 Q - where did you work specifically? 

9 A I was in the Chicago Field Off&. 

0 Q No, I mean as of March of ‘96. 

J A Oh. The Residential Protective Division. 

2 Q And that’s as the White House? 

3 A That’s at the White House, correct. 

4 Q Did you have a particular shift or ass&nent 

5 within PPD. start@ in March of ‘96? 

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protection around the President. 

Q Now, did you have an occasion - b mc back up. 

You’ve bocn with tbc PPD continuously since March of ‘96 ‘til 

today; is that right? 

A That’s correct. 

Q AndIbebevcyousaidyoualsoarewithtlx 

e0unIa3weillan#. tCz3m cumntly? 

A Countergssault team ri&t now. 

Q cOuntcrassaulttcam? 

A Yes. 

Q And wkn wl?t you assigned to that? 

A I went to countex-assault March of ‘97. 

Q And would yorr have brm ass&d to counta-assaulr 

5 once you Clisiui that training? 

6 A Yes. WdI, I started counts-assault March of ‘97. 

7 Q Isa. 

8 A And I’n bcm on couneassault since tbm. 

9 Q Isthstsomcthingthat-isthatadutytht’sa 

0 collateral duty to your other duties within the PPD? 

1 A If I could aplain - 

2 Q Please do. 

3 A - when 1 came 10 Presidential Prolcctivc 

4 Division, it has scvaal lhtlc units inside of it. as well. 

5 W’b 1 fmt got UJ Prcsidcntial Protccrivc Division. I was 

Page it 

I on a shiff and t& shift is work around the Presirknt. 

2 After a year or so. thy transfer agents to a 

satellite &tail, if you will, and that’s whar I’m at right 

now. I’m on a satellite detail. 

Q And your satellite detail is counter-assault? 

A Counterassault team. 

Q And you’ve been there since March of ‘97? 

A Since March, correct, March of ‘97. 

Q Give the ladies and gcntlcmcn, if you would sir. 

just a thumbnail sketch of what you do now with tb~ counterassault tram. 

A Counterassault. for lack of a bcncr word. is a 

SWAT team. if you will. TM’s it. 

Q Intheyearthatyouworkedashift-thatis. 

from March of ‘96 ro March of ‘97 - did you bccomc famihr 

with a Secret Service post near the Oval Office known asA Yes. 1 did. Yes. 

Q Describe for us where that post is. 

A Well. it’s ban a while since I pusbcd posts around 

tbe W-bite House. m if that’s tht co-t post. w’n 

talking about tbc Oval door. Is that what you’re refahg 

to? I don’t know wktkr -- I can’t recall wktbu it’sor Pl 

Q Okay. You made rcfamce to Oval door. tbz Oval 

door. Teii &e iadics and @niiemui about ibat post. 

Page” Tuesday, July 28,1998 

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1 A 

2 Q 

3 A 

4 Q 

5 area? 

6 A 

7 Q 

Can I check with c~un~l for a sewnd? 

Well, let me withdraw that question, then. 

okay. 

Do you feel that’s going to get into a security 

Yes, sir. I do. 

Let me ask a different uzy, then. During your 

8 shift work, would YOU stand outside a door that leads to the 

9 oval Office? 

0 A Yes, I would. 

1 Q And your recollection is this is known as eitherb 

2 rorm 

A Yes, it is. It’s one of the two. 1 don’t know the 

number off the top of my head 

Q Okay. Letmeaskyouif-andisthisknownas 

the main door to the Oval Offke? 

A ~‘mtqbgtoanwerhat. Imeaqtherearea 

number of doors, I guess. Can I talk to someone about that 

one? 

Q If you feel you need to, yon can. But let me see 

if I can get this a different way. 

A Okay. 

Q Is therr: a door that leads into the Oval Office 

that has a little table to the right of the door with a 

telephone on it? 

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Q And is this the door that you were talking about a 

minute ago -- 

A Yes. 

Q -- when you said that you would sometimes stand 

posts outside the Oval door? 

A Yes, sir. 

Q All right. If you’re standing looking at that door 

with the telephone table next to it, there an doors to the 

right down the hallway that led into the Oval Offke dining 

room and pantry: is that correct? 

A If you’re standing outside the Oval, at my post 

that we’re talking about, correct? 

Q If you’re standing outside. looking at that 

door -- 

A Okay.. 

Q -- where the telephone table is. 

A Are there doors to the right? 

Q That’s my question. 

A Yes, the are doors to the right. 

Q And those doors go into the Oval dini%_ room and 

_ . 

pantry area; is that corn+?- _ 

A I recall maybe One thai&les in&z I JIEa& 

4 that’s what I recall. 

5 Q An.6 when you say ‘goes in there,* it goes into the 

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dining room pantry area? 

A Goes into the pantry area, which eventually leads 

into the Oval and study, if you will. 

Q And then, as you’re looking at the Oval door, with 

the telephone next to it, to the left, down the hall, is 

where the President’s secretary sits, is that uxrect, Mrs. 

Currie? 

A ?bat’S COmt. 

Q And them’s also an entranCe into the Oval Office 

through the secretary area? 

A Yes, it is. 

Q Now, how many times would you say, in the year that 

you did shift work by that door, that you ever heard that 

telephone ring? 

A The telephone that’s by the post? 

Q That’s right. 

A Oh, Lord. I can’t recall. It rings. You know, it 

rings. 

Q Did you ever ring when you were on duty there? 

A Oh, absolutely. 

Q And when you were standing duty by that door, would 

you normally be alone? 

A Standing post there, sir? 

Q That’s right. 

Page 14 

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8 Q And then does Uniform stay in the hallway while 

9 you’re outside that door? 

0 A We’re within earshot of, or eyeshot of each other, 

1 correct. 

2 Q How many feet away would you say you are for 

3 Uniformed Division when you come on duty at that door? 

4 A Go with 15 yards. ‘Ihat’s just an estimate. 

5 Approximately 15 yards. or less. 

6 Q Agent Hightower, let me ask you if you know an 

1 individual by the name of Monica Lewinsky. 

8 A No, I do not. 

9 Q Have you come to know her through press reports, 

o since January of this year? 

I A Yes. Yes. 

2 Q Did you ever see her in the West Wing? 

3 A I vaguely recall seeing her in the West Wing. ’ 

4 Q What do you recall? 

5 A Asanewagentonadetail,youtrytoremember 

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faces. and 1 va&y rrmanba ba face. I mean. maybe press 

qorts and pictutu jarred rbc manory. YOU know. I might 

ranunbcr ha. 

Q Do you know an individual by tk name - an 

individual from tbt Uniformal Division - by the name of John 

Muskctt? 

A I would know Muskctt by fag if I saw him. Tk 

name_ it dasn’t - I can’t put tbz name with the face. 

MR. SUSANIN: Excuse mc for one saond. 

(Lntmruption to tbz pmcedings.) 

MR. SUSANIN: Let me state for the record that 1% 

b&n joined by one of my collcagucs from tk Indcpcndax 

GJunscl’s of&c Ed Pqc. 

BY MR. SUSANlN: 

Q Now. mt Hightowcr. do you recall working Eastu 

Sunday of 1996? 

A No,Ifan’tmcallwbctbcrIworkedthatdayor 

not. 

Q Did you routinely work holidays as part of your 

shift duty, from March of ‘96 to March of ‘977 

A Yes. we do. Yes. I do. Yes. I did. 

Q How fiqucntly would you work a major holiday? 

A You know. I - tbz frequency, I don’t know. I 

mean. tbc shift alignmcnt is done by tbc boss. and I - I 

5 don’t know bow ftqucntly I may bavc workal a holiday that 

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2 Q Inagivcnworkwuk.whatwasyournormal 

3 scbalulc? Did you normally work ~&days. wcd~~nds? 

4 A It dqmds. It’s not a tqular Saturday. Sunday. 

5 weekends off job. or mornings off or days off. 

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2 Q 

3m 

4 A5 Q..“.‘.“. 

6 A_ 

7 Q_ 

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1 Q Okay. I want to ga an undastanding for the grand 

2 jurors as to bow wakcnds factored into tk sckduk. 

3 A It’stbux,it’snoritymcorrcasontoit. Maybe 

4 tibzyputnewguysonVKckald. Idoa’tknow. 

5 But it depa~ds. You can work Wednesday tbrou& 

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1 - through Monday. and maybe you might not have a &Y Off 1 * Oval Office to Ict the Rcsidcnt know tLrrt sas a phone 

2 duringtbat~iftkschcdulcistight. It’snobtna 2 cau for him? 

3 way, I guess, I could describe that. 3 A No. I do not. 

4 Q In that year that you did shift work, can you 4 Q CanyoutcIItbclacbcsandgcrttlanmofrkgnmd 

5 -canyouestimateforrbegmndjurors,Iet’ssayina 5 jury bow frequently in that ~nar that you did shift work, 

6 gjvcll monrh, how many wedrcnds you would work? 6 fromMarrbof’96u,Marchof’97,youmwJdbciaeposition 

7 A It’shardtodo,butifIthrowsomc&ngout, 7 togoinand&tbtPrcsidentknowtbattbcrr~rp~ 

8 maybe 8 couple wukcnds a month I mean it’s bard. 

9 Q Do you zcmcmbcr, during tk time y:u did shift 

8 CalIForbiJn? 

9 A You wouldn’t be. mon or less. His dinct line 

0 work, an incidm wbae you and 8n off~ica from tbz Uniformal IO would probably ring. 

1 Division wue outside this door rhat W’M b&a SpcaLing 11 Q So. given your answp; if. in fact you did go in to 

2 about with tbc Mcphonc cabk wbm Monica Minsky came on 12 f%d fbc Prcsidcnt for a phone calL is that tbc t3pc of 

3 a Sunday to s& tbc Rsidcnt? 13 thing that would be unusua\ and stick out in your memory? 

4 A No, I do not. 14 A In my memory? No. Thae’s just so many things 

5 Q Could it have happened and you just Forgot if I5 that happen. R&Y, you could fom about some&& Now, 

6 S+aI Agent Hightowcx? 16 did &at happen to me? l&-huh. I don’t think so. No. 

7 A That’s possible, yrs. 17 Q Da YOU tym manbcr knocking on that door that 

8 BY MR. PAGE: J 8 I’ve b&n talking about to get a message in to tk Rxsidcn~ 

9 Q So. in view of that answ~. Officu, you can’t 19 onaed? 

0 exclude tbar ibat cvcnt &at’s btzn just dcsctibcd to you in 20 A No. No, I do not. 

1 fact happened? 21 Q Do you remcmbtz ever stepping into tbc Oval Office 

2 A Oh I can’t exclude whetbcz sk visited or anybody 22 to look for the P&dent. to get him a message? 

3 else visital. For that fact. 23 A No, I do not. 

4 BY MR. SUSANIN: 24 Q How many times, in the year that you did shift work 

5 Q Do you ever recall seeing Monica tinsky in the 25 at that doorway, would you ban gone in. would you have 

Page 18 Pag

1‘ West Wing on a weekend? 1 initiated going in to have communications with the Presi

2 A 1 hVe -- iike 1 say, i Vwity J#?&I k. And 2 A Never. We would never -- J would never do that, 

3 whether it was on a weekend or not, I don’t know. 3 Q Why is that? 

4 Q Well. can you give the grand jurors a sense of what 4 A Initiating communications With him wasn’t pan o

S the traffic through that area was like on a weekend, as 5 what I would -- I’m doing there, if you will, as I un&rsto

6 opposed to a weekday? 6 it. 

7 A Sure. Tra%c on the West Wing is minimum on a 7 Q If someone had come to you at that post with a 

8 weekend, 8 message, or with information to get to the President, how 

9 Q And how about a holiday? 9 would you have htidled that? Was there a procedure? 

0 A It’s probably about the same, or maybe less. It’s 10 A “Ihe staff people who would come there with a 

J not a lot of traffic in the West Wing on the weekends. 11 message for him, or whomever, knows to go around into 

z During the business days, there’s a lot of traffic, there’s a 12 secretary’s office or, if he’s expecting them, they would g

3 lot of people. 13 right in. 

4 Q Do you ever remember an incident shortly after you 14 Q And how about if they had a message for the 

5 started shift work -- and you had never done PPD work before IS President and it was on a weekend, so the s~chtary wasn

6 March of ‘96; is that correct? 16 there? 

1 A That’s ~0rrecC. 17 A They would walk right in through the secretary’s 

B Q Do you remember an incident, when you were still 18 off-ice. 

2 fairly new to shift work, in the West Wing, where the 19 Q Is that locked or unlocked on the weekends? 

3 operator called to that table, the phone on the table that 20 A I beiieve it’s locked. 

I we’ve been talking about, saying she had a call for the 21 Q So how would they get in? 

2 Resident, but he wasn’t picking up inside the Oval? 22 A We would have to let them in, I believe. 

3 A No, I do not. 23 Q And how would that take p@ce? 

5 Q Do you remember an incident shortly after you 24 A Key. Wehadakey. 

5 started shift work in the West Wing where you had to go into 25 Q 1 mean, what kind of verification would you do? 

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! 1 Q Are. there two Southwest gates? 

8 I 2 A There are some -- thxe are - yes, ccmect. 

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1 A Well. you would see the people by sight. and they 

z have a pass, a hard pass. Do I need to explain that? Okay. 

3 Q Now, you’ve testified that you believe the post 

4 that we’re talking about is either’ or m -- 

5 A Yes, sir. 

6 Q-- is that correct? Do you know of a post at the 

- ..” .-- TV~ ~~ ~___I__. A-L---_1 -0 1 w l-me rioux compIGr;x u=ll;n~LCu v ! 

8 A m? No, I do not. I don’t recall that. 

9 Q And how about a post designated_? 

0 A Yes, I know-, but f know it’s a gatepost. 

1 Q Which gate is that? 

2 A If I saw the diagram, I could tell you. I can’t 

3 recall off the top of my head. 1 mean, I know the post, 

4 but -- 

5 Q Okay. Let me show you a diagram that’s been marked 

6 as Grand Jury Exhibit, we’re going to call it your initials, 

7 which is RH. Do you have a middle initial? 

8 A No middle initial. 

9 MR. SUSANIN: All right. We’ll call this RH-I. 

0 (Grand Jury Exhibit No. RI-I-1 

1 was marked for identification.) 

2 BY h4R. SUSANIN: 

3 Q Do you recognize what that is a chart of, Agent 

4 Hightower? 

5 A Yes. It’s the White House orour&. 

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4 A 1 know where- is. _ iS this one righ 

5 here, because that’s the place we take our tours. 

6 Q How about-? 

7 1 A--,_ ,____. ._.I-_- -:_ _A -_ A 1 uon 1 Know wrlrrLY k-15 ar, nu. 

8 Q* 

9 A No. 

0 Q-? 

1 A No. 

2 Q-? 

3 A Oh, no. 

4 Q Do you know where a is? 

5 A -? Yeah. Again, that’s-another one of the 

6 gates hcrc.It’s either up here - if you want me to mark 

7 something on here, I will. I believe it’s this one right 

8 here. 

9 Q Can you mark where you believe it is? 

0 A I think -- yes. I will mark Where 1 believe’ 

1 is. 

2 Q How about -? 

3 A I’m running out of gates, now. m would be this 

4 one right here, I would believe. 

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Q Okay. Arc you able to point out on there where 

Gage m is? 

A Yes, sir. Sir. it’s -- again. I mean, the post is 

not on here, but it’s one of these gates around here. But 

this is u. This might hem right hem, sir, east 

appointment gate 

Q I’m going to ask you to put I) on there, with the 

pen. How about a Do you know where that gate is? 

A -might be this one. 

Q How aboul~ 

A Idon’tknowwhichoneis-mmightbethe 

visitor’s center, I guess. I don’t know. I’ll put it there. 

Q Now, are you guessing? 

A Well, I mean, I’m trying to recall. -l-he diagrams I 

looked at got the post on there. And I mean, there’s So many 

gates. I know where the entrances are to the White House. 

but if you would ask me, “Reg, is that m or_,” well, 

yeah- I think that’sm, correct. 

Q Do you know where m is? 

A I_ Yeah,Iknow_offthetopofmy 

head, but I couldn’t mark it on tbe diagram. 

Q Can you tell me where it is? 

A I would believe- is - I know it’s a south 

gate. It’s maybe the south -- that’s_ -- Southwest 

1 

1 A 

2 Q 

3 A 

4 Q 

5 A 

6 Q 

7 A 

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_ 1 don’t know wherem is at, sir. 

How about-? 

I’11 put this one-. 

Is that where you believe- is? 

That’s where I believe it is, yeah. 

I-Iow about _ 7 

I would look at the diagram. I’m trying to recall 

6 these gates. No, B, I don’t know. No. 

1 Q-7 

3 A No. No. 

I Q-? 

2 A No. 

3 Qm? 

4 A No. Okay. Keep going. 

5 Q -, do you know where that is? 

6 A m? No. DoyouwantmetotellyouonesIdo 

7 know? 

B Q Why don’t you? 

9 A All right. 

1 Q Arethereanyonthuetbatyouknow? Letmask 

I you one more before you do that. 

z A Okay. 

i Qm? 

t A _ That’s -- I know that’s in the Old 

r , e..__...:.._ r\lll__ m..:,>;:_ ___-_..L_-- --.l- .L- __I-. &L. ~~ * 

CAGtulL”C “Jllce lJlJnuJ”g soJnewrlGre. ,rlar-s ule only KJJJJg J 1 

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I cantcuyou. 

2 I know it’s - most of ml.* m. As. have 

3 kind of got a designation, you can kind of ncall whcrc 

4 tbcy’w at. But again, I haven’t looked at a &p in a whik. 

5 Q k xnc ask you to mark tbc Old Excrutivc Build& 

6 0o &at chart witha, thm. You b&w? it’s sonnwkcrc in 

7 the Old Executive? 

8 A YCS, sir, I bclim~ it is. Yczd~ I know it’s in 

9 tbc Old Exccutivc. It’s aa. It’s aI). 

1 0 Q Can you e an Old !Zxrcutivc tbzzc? 

1 I A No. I tell you what. I probably - tk one that 

1 2 I’m m0st familiar with with the number, would probably bc* 

1 3 soab&ing, wkrc you go into tbe cndir union. at tbc main 

1 4 amancc wbac most pmplc go into tk credit union. It’ s 

I 5 off of Pulnsylvania - 17th stlzt. 

1 6 Q And that’s a@ gate? 

1 7 A It’s a @gats wrrect. 

1 8 Q L.ct mc back up and ask you about s0mctb@ you jusr 

1 9 said that the differan ldlns have diffacot designations. 

2 0 Art ail etcs in tk Old Exccutivc Building? 

2 .1 A Can I just hold on that one? I haven’t said it 

2 12 right. Ycab. Mostly, I would assumcm arc in the Old 

2 13 Exautive Office Building. Correct. 

2 :4 Q Aod how about m and(l)? 

2 !5 A C and l ,_ arc probably the south grounds ande 

Page 26 

I are closer around the mansion, if y0u will. 

2 Q And how about _? 

3 A As would he your north ground gates. 

4 Q Are there different gates designated for different 

5 groups of people that have access to the White House? In 

6 other words, do White House employees use certain gates? 

7 A I would say yes to that, for the most part. 

8 Q Which gawk do White House employees use? 

9 A Weli, let me put it to you this way. To get in the 

1 0 complex, there are a number of gates that you can go through. 

1 1 Groundkeepers. Park !Gervia &ople that take care 

I 2 of the grounds, the butlers, the social secretaries and stuff 

1 3 like that, they can enter any of these ga& around the 

1 4 complex. 

1 5 Now, is the question what gate do visitors go 

1 6 through that’s on offXal business, or what gate would a 

1 7 staff person go through? 

I 8 Visitors would go through the appointment gates. 

1 9 The appoi!tment gates that I know of for sure again, is 

21 0 -- well, this is written on there. The appointment gate over 

2 1 here, the east appointment gate, and the southwest 

2 2 appointment gate, and the qorthwest appointment gate, those 

2 3 are the three that some visitors would+go,through. 

2 4 Q It sounds like you’re breaking up people that work 

2 5 attheWhiteHousei-l Pagem Tuesday, July 28, 1991 

Page 2’ 

1 A Yes. 

2 Q -- to people that,_are staff- in one category, 

3 and people that actually’ are White House employees, maybe 

4 beyond administration -- 

1 

5 A Yes, sir. 

6 Q -- on the’othr. As you said grow 

7 butlers, that kind of a thing. 

8 A %s, sir. 

9 Q Do staffers use different gates from those 

0 emplo*$ees? 

1 A That’s a possibility. Yes, sir. 

2 d Do you know? 

3 A Do I know that they probably go through other 

4 gates? Yes,&. 

5 Q And explain your answe+r. 

6 A Again, through either of those checkpoints there. 

7 They can go through the east gate, the north gate, the south 

8 gate, or -- the visitor’s center -- east, nor& or south. 

9 Q And who are you talking about now -- 

0 A Thestaff. 

1. Q -- the stafkrs or the employees? 

2 A Staffers, to&ir. 

3 Q All right. 

4 A “With the passes. You have to have a pass. 

5 Q Okay. So staffers have a certain type of a pass? 

Page 21 

I A &s;sir. 

2 Q And do dti*pata require thar type of pass? 

3 A Yes, sir. catain :entry into certain parer of 

4 the compound dots rrquirc a certain pass. 

5 Q Okay. TeU us about that. 

6 A Passes arc color-c&d. and - can 1 la&t witi 

7 these guys about this? Just about thcr+ sir. 

8 Q Okay. We& kt me dcfa that question for a few 

9 moments. then. 

0 A Okay. Stuc. Sure. 

1 h4R. SUSANIN: Let me Speak with my col!eaguc for a 

2 moqt. 

3 (Counsel confared.) 

4 BY MR. SUSANIN: 

5 Q~AllrigJtt. l_ctmegobacktoanincidcotmwae 

6 talking about bcfor~ Special Agent Higbtowu. 

7 Let mc ask you. if Ms. Lcwinsky came u, visit the 

8 President on a holiday weekend. when you WQC working the 

9 shift there, and had baz~ h in, is that the type of thing 

3 you could have forgotten? 

1 A I could have forgotten it’s a holiday wa)rcnd 

2 correct. Oh, yes. 

-. 

3 Q WfU, if sbc bad catnc’to see tbc Prcaibmt and was 

4 let in, is that tk. type of thing that could bavc bappaxd 

5 and you just don’t mbcr? 

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I A Oh, absolute@ 

2 Q Okay, So is It your testimony in f&t of the 

3 grand jury -- wetl, let mc ask it this way. You’re not 

4 saying to the grand jury that that ~YPC of sirJatioo could 

f not have happened? 

6 A Right. I’m not saying that she could have COnYE 

7 there on a wcekeod and -- and I’ve forgotten, yes. She could 

8 have come there, and I just did not realize it was her, and 

9 it was a weekend. 

0 Q Now, how about you going into the Oval Office to 

1 pass a message or to othczwise look for the Prcsidcnt? IS 

2 that the type of thing that could have hap@ and you’ve 

3 just forgotten? 

4 A Yeah. Yeah. That’s true. I mean - no, I -- no, 

5 Iwouldn’thavedoncthat. Iwastoonewandtoojittery. 

6 Q And explain what you mean to the grand jury. 

7 A I--~t~in~~you’m~nga~~Ij~ 

8 would have membered probably doing that. 

9 Q Okay. Given that you were new in tbc spring of 

0 ‘96, if there was a message or information that had to get 

I through to the President during a weekend or a quiet time on 

2 the West Wing -- 

3 A Yes, sir. 

4 Q -- is it likely you would have asked someone else 

5 to go in with you to look for the President or to go in and 

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look for the President on your behalf’? 

A Oh, absolutely. That could have happened, yes. 

Q And that’s something that could have happeocd? 

A Oh, absolutely. Absolutely. 

Q What types of pcopic would you have reached out to 

to do that” 

A If the phone had rang, and someone had said, “I’m 

looking for so-and-so-and-so” -- the President in this case 

__ the Uniform guy, we look to those: guys for guidance. ‘IIq 

help us out, the new guys on the shift. 

Q Why is that? 

A I mean, you’re standing there, you don’t know all 

the faces, you try to recognize the faces and remember the 

faces, and you don’t know all the procedures. So yes, it’s 

very possible that a Uniform guy could help you out. They 

help you out. They’ve been around a while. 

Q ‘They’ve been around a while and they know the 

shift? 

A Well, they know that you’re new, for sure. and they 

know all the players, the people that are waIking around the 

West wing. 

Q Do you recall in those weeks when you were new to 

the Oval Office ever asking Uniformed Division offtccrs to 

help you with anything that came up on the job? 

A I don’t recall, but it could have happened. I’m 

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SKIT tt happcnod. 

Q Now. you staral autia thar you had xnc vague 

ncolkstions of Monica Lewinsky that was jancd by tbc press 

rckasesofczvIicrthisyavA Yes. 

Q -andreportsintbcmaGa;isthatri&? 

A Ya. sir. 

Q Now. as you’re talking bzc about March of ‘96 

through March of ‘97. when you’re doing shier murk. is your 

nxmory jartcd any furtbcr about seeing Monica Lewinsky in the 

west Wing? 

A Nothingotbcrtbansceingbcrwalkpastmonpost 

andmaybetvrnrunanbcxinghan~Monic&. 

Q Andbowwoulditbetbatyouwouldkuowbuname? 

A I would ask, maybe, tk Uniform guy, bzausc 

sometimes. again. you know. being new, you dm’t know all tbc 

faces and .m and you don’t want to stax at rhc passes. 

“Who is that?” And maybe someone would say That’s so-andso.” And so that’s, you know, whoever T- w the pcnoo 

was. 

Q And you r*;tifii carlkr. when WC war talking 

aboutstaffaswtr,~twanttogainwithamssagctasa 

tbc Pnsiduxt on tbc S&C&+ tbiu you would frqumtly know 

them by faces. cspccially if you wax going to b t&n in. 

Wastbatpartofyourduty.asyousewi5aJpart 

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of the PPD. to recognize those pcopk tbat were in and around 

the West Wing when you were doing shift work? 

A Is it par? of my dutis to rsognize pmpk tbat 

are in tbc Wst Wing? Is that the question. sir? 

WotidyoutxytoOh yts. sir. 

- kam t&z fats? 

Oh absolutely. yes. sir. 

And why is that? 

Well, it’s a security issue for one. Andjust 

because tbey’rc in tbc West Wing, you know. bopcrutly no one 

didn’t wanda in tbm that wasn’t supposed to k. 

And you Just try to raognizc tbc faas. You want 

to rozognizc tbz chkf of staff. You want to w tbc 

press sccreuuy. You want to xcCcgni2.e tkSe peopl, because 

you don’t want to be stopping than asking than fa their 

pass. 

Q And you mentioned a moment ago that you might bavc 

askaisomumc’Wnoisthat”withtxgardtoh4s.Lewir&y. Who 

arcyouas~aboutwbcnyouarc~ngtof~antht 

identity of faces that you’re sa5ng when youk nc~ in the 

WCs1 Wing? 

A A Uniform offi. specially those tbat been 

around And tbcy have brm around. 

Q b you rcmanbe asking a Uniform offi Ms. 

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I Lewhsky’s name? 

2 A No. I probably did, but I can’t rananbcr it. 

3 Q But you rcmanbu that you knew her as Monica? 

4 A I just mnanbcr tk. mmc Monica, sir. Yes. sir. 

5 Q And you runanbcr that as something you knmbcforc 

6 th: prss IcpoRs !zanx out carik this ywr? 

7 A The press report probably jamxi the memory. my 

a memory, but again I mean, maybe I mmanbcr the name, Monica, 

9 fram, being on the West Wiq& Sir. 

1 0 Q You mcntional whm we wsc rcvicwiug Grand Jury 

1 1 Exhibit RH-I that this is a LittIc diffucnt from tbc chart 

1 2 that you normafly lank at.. 

1 3 A Yes. sir. 

1 4 Q Okay. Andwhat cbartistbat? 

1 5 A WC& th: gates. J IIYB~. it’s tk same grounds, 

1 6 but the gates arc numbaul and lab&I. I mean. I could 

1 7 point tom and you could. too. bccausc it’s on than. 

I 8 Q Okay. So tbc chart you’re matking about - 

1 9 A Yes. 

2 10 Q - would actuaIIy bavcm printed on tbc chart? 

2 !I A Ys. Yes. 

1 !2 Q And what chart is tbat you’re taIking about? 

2 !3 A We& that’s anywbcre in our offices. or wbcrcvc~. 

i :4 you know. wberc w&m at. 

2 15 Q So it’s tbrougbout tbc different postings or gates? 

Page 34 

1 A Not necessarily. But I moan, in your packet when 

2 you come to the detail. you have a gate post Iike this, 

3 compound post map. if you would. 

4 Q So it’s something that goes out to most Sccrct 

5 Scrvicc anployccs working at tbc White House? 

6 A Yes. Yes. sir. But the pats, lika or _ 

7 or this one over bcrc, tbc cast appointment gate. I think tbz 

8 public know, staff people would know. maybe, the nttmbcrs, 

9 too. I don’t know. I really don’t. 

1 0 Q Okay. But it’s fair tn say this is not some super 

I 1 secret chart that you’re talking about. this is something - 

1 2 A Oh. no. you got it. No. this is -- 

1 3 Q If you could, just let me finish the question. 

1 4 A Ycs.sir. 

I 5 Q The chart that you’re talking about. that has tbc 

1 6 _ designation on it. &at’s a cbarr that’s passed out to 

I 7 all of you wbcn you begin anploymcnt with the Secret Scrvicc 

1 8 at tbc Wbitc House? 

I 9 A Yes, sir. Ibcbcveit is. 

2 10 Q Okay. 

2 !I A 1 mean, for the agents. sir. 

2 :2 Q And where would WI: get a copy of titat if wt wanted 

2 13 to see a copy of that? 

2 !4 A With tbc numbers on tbcm. sir? 

2 

Page 3! 

1 A Sccra %x-vice, sir, I guess. 

2 Q And what off~ca+, who within tbc .SCZIU *ice? 

3 Isthatsomethinethatwouldbcin~orintbccammand 

4 center? 

5 A Oh, ych. Yes. sir. You could find this intJ 

6 with the numbers and krttcrs, for sum, sir. 

7 MR. SUSANIN: Agent Higbto~, I’m going to ask you 

8 to bcnr with us by stepping outside tk door - 

9 THE WITNESS: Yes, sir. 

0 MR. SUSANIN: - for a few minuets. 

1 THE WlTNESS: Okay. 

2 MR. SUSANM You can just wait outsi& tbc door. 

3 Wc’llbcwitbyouina mDnrnt or two. 

4 (Witness excused. Witness rccahcd.) 

5 MR. SUSANIN: Have a sea4 Special Aguu Higbtomr. 

6 THE WREPERSON: Agmt Higbtowu. do you undustand 

7 you are stiu under oatb? 

a THE WlTNESS: Yes. I do. 

9 THE FOREPERSON: Okay. 

0 BY MR.susANR+ : 

1 Q Fit% Special Agent Hiightowa. kr mc ask you, I 

2 bcIiivc you mentioned carbu in your testimony that tkre 

3 wcm some gate numbers or designations that 1 didn’t ask 

4 about. that you might know of. In o&r words, I think you 

5 said. “Do you Want me to mark tbc ones I do know?” 

IS Q The chart you’re taIk.ing about. 

Page 36 

1 Did you get to finish that process, or are there 

2 any others you could mark on that exhibit for us? Can you 

3 just state for the record -- 

4 A Yes. Yes. I’m marking _, m. I 

5 tinkthis_o~isoneofthctwo. oursismana 

6 in there, inside the building itself, inside the West Wing, 

7 the Oval door, and the secretary’s offke door. 0 is 

8 one that we pushed posts on. 

9 Q whereis_? 

0 A - is right here, sir, on the grounds. 

I Q Can you state for the record, what you’re talk& 

2 about? It’s outside what? 

3 A m is outside. It’s an outside post, not 

4 too far from the putting green, you know, golf green. 

5 Q How about _? 

6 A _ is the diplomatic entrance, the south 

7 grounds. If you looked at a picture of the south grounds, 

8 that door that’s right there, you go right into it. just 

9 straight through. 

0 Q Andarethereanyothersthatyoucanthinkof? 

1 A _isthisone. 

2 Q-‘-? 

j 4 ~-,~isbytbepxssroom,theOval 

4 colontmcle, if you will. That’s a lot of them, sir. 

5 Q Any others? 

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I m. And that’s tt, Sir. That’s pretty much it. 1 Q And wIxn you do advana work. is that to advance a 

2 And whae ia? 2 place that the President is visiting? 

3 _ is inside the mansion, inside the house itself. 3 A Yes. sir. 

4 Okay. And where inside the house is it? 4 Q Okay. So you haven’t worked for instance. say, 

5 ‘Ihe ground level, right by the diplomatic entrance. 5 the Oval Office door. since you’ve moved to cotmtu-assault? 

6 Now, when you moved in March of ‘97 to the cuunter- 6 A Oh no. Oh. no. I haven’t worked rhx since 

7 assault -- 7 this. 

8 A Yes, sir. 8 Q If you’re working countcr-assauI~ and ti was an 

9 Q - is it corm&r-assault team Or counter-aSS.aUtt 9 incident at one of rhc 8atcs. and gim some of your 

1 0 unit? 0 testimony about being a link shaky on some of the gates. 

1 1 A COUnter-a.SSaUit team, Sk. I bowwouldyougettoaparciftbcrrwar:anincidenttbcre 

1 2 Q Counter-assault team. Did you actually stay at the 2 whik you wue on duty witb coumn-assault? 

1 3 Wl&e House? In other words you still work at the White 3 A Thisoneihavctotalktotbcguysabout. 

1, 4 House? 4 Q Okay. Do you want to talk to than now? 

1 5 A Oh, yes, sir. I’m still on the Pre&?tSiaI 5 A Yeah about that stuff. Excuse me. 

1 6 Protective Division, yes, sir. 6 (Witness excused. Witness recalled.) 

1 7 Q Okay. So you don’t work elsewhere since March of 7 MR. SUSANIN: Special Agent Hightowu~ hava you bad 

1 8 ‘97, you still work at the White House? 8 an opportunity to consult with your counscf? 

I 9 A I’m still a part of Presidential hotfhve 9 THE WITNESS: Yes, sir. 

2 0 Division. And work at the White House. sir? I mean. I .don’t 0 THE FOREPERSON: And Agtnt Hightower, you 

2 1 do the post around the White House. No, sir. Is that what I understand you are still tmdcr oath? 

2 2 the question is? 2 THE WTPNESS: I understand. 

2 3 Q Right. Where do you go to work each day, as part 3 MR. SUSAN-M Thank you. h%dam Fotcpasson. 

2 4 of the counter-assault unit? 4 BY MR. SUSANIN: 

2 5 A Our offices is in the New Executive Offke 5 Q Let me ask the question again for tbz accord. And 

Page 38 Page4. 

1 Building. We cower motorcade movnnents and the President’s 

2 movements. basically. 

3 Q Okay. 

4 A Yes. sir. 

5 Q So you’re still wbare the E’residcnt is, as pm of 

6 the counter-assault unit? 

7 A Yes. sir. But - but I’m not in a suit. 

8 Q Okay. If’ be’s in the White House, wbcm are you? 

9 A I’m in the New Executive Office Building. 

0 Q Okay. And if be’s traveling. am you traveling 

1 withhim? 

2 A If my team is traveling. yes, sir. 

3 Q So. as part of the counter-assault unit, you don’t 

4 work the gates? 

5 A No. sir. 

6 Q Okay. Have you ever done any shift work on a fill7 in basis or a temporary basis since you’ve been with counter8 assault? 

9 A Yes. sir. 

0 Q Okay. How many tlmes would you say, smce March of 

1 ‘97? 

2 A Oh, sir. I can’t recall. It would be a number of 

3 times. Advances. no actual shift work. if you will. but 

4 advance guys come from shifts. So advances. more than 

5 anything. 

I again. this is a qustion from one of tbz grand jurors. 

2 

8 c 

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6 Q And to follow up, it sounds Iike, sirtee you’ve 

7 stoppal doing shift work, you’ve b&n working at tk 

8 Executive Offia Building? 

9 A Yes, sir. Yes. sir. until we @ in the truck and 

0 go over and pick up the motorcade and kave 

1 Q Let me ask you about your rneoIkction of Ms. 

2 Lewinsky in tbetWest Wing, as it was jarred by media accotmts 

3 of earlier this year.? 

4 A ‘Yes, sir. 

5 Q Oneoftbegrandjurotsbadthcqustionas!o 

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1 wkkr you nmanbcr Ms. kwinsky cmying anyrhing or 

2 holding anything wh you would see kr in the West Wing? 

3 R No, sir. I can’t remember that, no, sir. 

4 Q&P rananbcr q&ing clsc about kr that would 

5 ~~~~~~dj~? 

6 A No, sir. sbt’s emactivc I think and thet t&s 

7 yourcmembawhopcnplt~Igucss,~. 

8 Q Canyoudcscribcwb%~sb:wasinwork8nircor 

9 &da*? 

0 A No. sir. No, sir. 

1 Q You rcstif-I&, in response to my question, that it 

2 was pcasibk that th pbonc outside the Oval Office door 

3 couldhavcrungwbenyouwereondutyttnc. Andoneoftk 

4 grand jurors wamaI to know if it’s possible that did not 

5 l=PP= 

6 A 04ys. sir. But tbcphoncwouldring. Imean. 

7 itwouIdbavl:rung. 

8 Q Yeah. I asked you wbethu it was possible, about 

9 an incident wbxe tbae was a phone call fmrn someone loolring 

0 for th: Frcsident and couldn’t find him. I belkve YOU 

1 tcsCfnl you don’t recall that incideut. 

2 A Yes. sir. 

3 Q AndIaskcdyouiftbatincidcnt,ifitwas 

4 possibk that that happen& is that right? 

5 A Yes, sir. Oh,ys. 

Page 42 

1 Q And you said it was possible? 

2 A Yes, Sir. 

3 Q And the question is, from one of the grand jurors, 

4 is it possible that that did not happen? 

5 A Yes, Sir. 

6 Q And given what I think is fair to say, your lack of 

7 memory about such an incident, if I were to represent to you 

8 that, in fact, there was a time wheo that phone rang while 

9 you w on duty there, from someune who was trying to get 

0 through to the Oval Office and couldn’t find the President, I 

I take it that ybur testimony is it’s possible that that did 

2 happen? 

3 A oh,yes, sir. 

4 Q Let me ask you, with regard to going into the Oval 

5 Office to look for the President to tell him about the phone 

6 CL&, again, you testified that it’s possible that that 

7 happened. 

8 And one of the grand jurors has a question, is it 

9 possible that did not happen? 

3 A Oh, yes, sir. And again, let’s just take that 

I phone call for an example. If that phone had rang, and I 

2 picked it up, or the Uniform guy there picked it up, being 

3 the new guy on the detail, I would have let him handle it. I 

1 know that for a fact. I would have let him handle it. 

5 Q And when you say you know that for a fact, do you 

Page 4 

I have a reCoIk&on of ever deferring to tbc Uniformal 

2 Division to handle incidents like that? 

3 A You know what? I can’t KC& but I know I’ve 

4 bccnfhxwbenithappcncd. 

5 Q Tell tbc grand jurors what you mea whn you say “I 

6 know I’ve b&n tkzc when it’s happened.” 

7 A ~p~~~~~orana~~~gooff~ 

8 som&ng, and I la t&n know.” 

9 Q ~~~kyo~~I~~~~t~you~~ 

0 in fact, tkrc was an incident Whcm you wrnt into tbc Oval 

I Office to lo& for tk+ President about a phone call, do you 

2 still maintain tbar it’s possible that that happened? 

3 A I don’t understand tbt question, sir. 

4 Q IfIwactorcprscnttoyoulhatthcncwcrcan 

5 incideut when: you and a Unifonuai Division officer went into 

6 tbe Oval Office. stepped into the doorway of tbc Oval Off~cc 

7 lolookfmLbePrcsidcntbccauscofaphonecaUthnthad 

8 come for him, is it possibk that happened7 

9 A it’s possible, sir. 

0 MR. SUSANIN: I’m going to ask you to step outside 

1 again. Ageat Hi&tower. 

2 THE WITNJXSS: Yes, sir. 

3 MR. SUSANIN: Thank you. 

4 (Tbz wimess was excusai at IO: I 1 am.) 

5 *eon. a luncheon zcczs was taken.) 

Page 4 

1 l **** 

2 wllucupon, (2:20 p.m.) 

3 REGINALD HIG~OWER 

4 was recalled as a witness and. having ken prwiously duly 

5 sworn by the Foreperson of !he Grand Jury, was examined 

6 further and kstitid as follows: 

7 THE FOREPERSON: Good afrernocm. Mr. Higbtowcr. 

8 You understand you arc still under oath? 

9 THE WITNESS: I understand. 

0 THE FOREPERSON: Okay. 

I EXAMINATION 

2 BY MR. SUSANIN: 

3 Q Good &moon, Special Agent Hi&tower. I have a 

4 few additional questions for you from the grand jurors. 

5 A Yes, sir. 

6 Q First, I want to ask you whether you felt you had 

7 ample opportunity to consult with counsel during your 

8 appearawe hae in tbc courthouse today? 

9 A Yes, sir, concerning Ibe things that I was 

3 conccmed about, yes. sir. 

I Q Okay. A second question from a grand juror 

1 regarding your testimony that some of the media accounts 

t involving Ms. Lcwinsky that appeared earlier this year, I 

t think to use your pluavc trim your manory - 

5 A Yes. sir. 

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Q -- about having seen her in the West Wing; do you 

recall that testimony? 

A Yes, sir. 

Q And the grand juror would like a little bit of 

clarification as to what exactly - what memories exactly 

were triggered by the media account as opposed to you 

adapting some of what you saw in TV into your recollection. 

Do you understand the question? 

A I understand it. It’s just the face, putting a 

face there more or less is what I remember. It’s, I’m 

saying, well, you know, I remember that, remember her, if yo 

will. 

Q Okay. 

A Yes, sir. 

Q Let me ask you, as a followup to that, then, how 

bright a line can you draw between what you saw on TV and 

what is your recollection from before this story broke? 

A Nothing. It’s just another person, if I understand . 

the question correctly. 

Q Yeah. In other words, are you certain that your 

recollection is really what you remembered from before this 

incident broke? 

A Yes. Yes, sir, and here’s an example. Just over 

lunch, x remember the posts, 00w.m andm and m 1 

know where those are at. 

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And, about the telephone ringing, I can kind of 

almost remember that. And not me answering the phone, but 

maybe the UD officer answaing the telephone and saying 

something about the President or “‘The operator, he’s looking 

for the” -- I don’t know. But it just, it comes back a 

little bit. 

Q Okay. 

A I don’t remember, really, I can’t say 100 percent 

I’m sure about that, but 1 cm almost remember that, sir. 

Q Okay. Let me ask you, then. just in light of that 

statement, if you could explain in a little bit more detail 

what it is that you remember when you say over lunch you 

remember about a phone call coming in. 

A Right. I just, you know -- 1 can’t say a blanket 

letter, “This is what happened” On the weekend, it’s not 

that much traffic over there. And, being the new guy on the 

detail, I didn’t know a lot of procedures. And again, as I 

explained to you earlier, the Uniform guys help out the new 

ICVs. 

So I can vaguely recall maybe an incident like 

that, where the phone rang and he was looking for the 

Resident, the Uniform guy, that is, and I happened to be 

there, and maybe going into the Oval or something 

I don’t remember going in there, but I mean, I just 

- I don’t know whether you’re triggering it or it’s 

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Page 47 

something that I remember, but yes, sir. 

Q Okay. Lrt me. try to ask you a bit mote about that. 

When you say you have a vague rccoIIe&m of a phone Cat’ 

coming in -- 

A Yes, sir. 

Q -- what is it that you do remember. as you sit 

hem today? 

A Just this, sir, that maybe a phone call came in and 

-* I can’t remember. It had -- I know it was probably on the 

weekend, for sure. I know that’s for sure. But a phone call 

coming in, wming in and he’s taking the call. And I don’t 

remember what guy it was. But he’s taking it_ And -- 

Q When you say “he,* is that -- 

A The officer, sir. 

Q Is that someone from the Uniformed Division? 

A Yes, sir. Yes, sir. And maybe saying something 

like “Ihe operator is looking for the Pmsident” or 

something. I -- just that’s what I remember, mom or less. 

Q And do you remember what efforts wae undertaken to 

locate the President? 

A I believe he might have - he might have went into 

the Oval or knocked on the door or something. I can’t 

remember. It might come back. 

Q And I know it’s difftcult, but let me still probe 

what you do remember -- 

Page 4, 

1 A Yes, sir. 

2 Q -- or what’s come back to you over lunch Do you 

3 recall that this was a weekend? 

A I’m sum it was a weekend. 

Q Okay. And how -- you testified earlier today that 

you started in March of ‘96, doing shift work? 

A Yes, sir. 

Q Can you tell the ladies and gentlemen of the grand 

jury, if you know, how soon after you started in March of ‘96 

this took place? 

A Ithadtohavebeenearlyon. Imean-Imcan, 

that’s when you’re trying to Learn everything. And I mean, 

ithadtohavebeenearlyon,sir. BythetimetbatIleft 

the shift, I know it wasn’t then. At least I think it 

wasn’t. 

Q DoyoumealIwhetbert.hepersonontbeIinehad 

triedtogetthroughtotheOvalOfficebytbetimthey 

called to you and the Uniformed Division off&r? 

A At that post, called to that post? I don’t know, 

sir. I mean, I don’t know. 

Q Areyousayingthatthcphonccallthatyou’n 

talking about did come to that table right next to the Oval 

door that we were talking about? 

A Yes, sir. Yes, sir. I 

Q Do you have any &e&z&m how it played out? I 

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n rer Grand Jury proceedings Mul 

Page 4’ 

A No, sir, I really don’t. Tk things that I cao 

remember, again. is maybe something like that happing. And 

I wouldn’t tell you I’m 100 pcrfcnt sux kcause I want to 

k 100 pawmt sure, but I may can nzall that incidart. I 

don’t know. 

Q I’m sorry? 

A I can probably mall that incidcat. I oxan, I’m 

not saying I’m 100 paccnt surt oo it. But that could have 

happcaed for sure. 

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haPpcn. 

MR. PAGE: What did you bave for lunch? 

MR. SUSANIN: Excuse me for one m-t. 

BY MR. SUSANM 

Q Do you xcall, Special Agent Hightowu, during this 

incident, whet&x the Prsidatt Was in the Oval Office? 

A WeUsir,khadtobavebaarowintbcOval 

Office, because I was there. He would only be tkre if we’re 

thue. 

Q Okay. So tk fact that you wuz tkm means k was 

there? 

A Yes, sir. 

Q Anddoyou runanbcr. as you try to sit back and 

mnanbcr this in&cot. do you remanba iraring tbc sound of 

Page 5C 

his voice at any time, and maybe trying to locate him or -- 

A No, sir. No, sir. 

MR. SUSANIN: Yes, please do. 

BY MS. WIRTH: 

Q I’m Mary Anne Wirth. Do you have any memory at al 

of whether the President had a guest, a visitor, at that 

time? 

A No, ma’am. 

MR. SUSANIN: Sir, if you could bear with us again 

and step outside, we’ll be with you momentarily. 

(The witness was excused.) 

(Whereupon, at 2:29 p.m., the taking of the 

testimony in the presence of a full quorum of the Grand Jury 

was concluded.) 

l **** 

Diversified Reporting Services, Inc. (2021296-2929 

Pagem Tuesday, July 28,199’ 

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1426 

Wmte House Area Map rage 1 oi i 

Constitution Avenue +Washbrgton MonWnent 

White House Tour Information 

Public Events Calendar 1 Event Descriutions 1 White House Map 

xecutive Oflice Building Tour 1 Jamehe Kemedv Garden Sculuture Exhibits 
1427 

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

-IOFFICE OF THE UVJIEPENDENT COUNSEL, 

Date of transcnprion 2/12,‘98 

JOHN LEE HILLEY, white male, 

Social Securit Account Number t-, bornw. 

4-4, m -, telephone number - 

was interciewed in the Conference Room of the Office of the 

Independent Counsel, 1001 Pennsylvania Avenue, N.W., Suite 490 

North. 

After being advised of the personal and official 

identities of the interviewers and the purpose of the interview, 

HILLEY provided the following information: 

Since February 6, 1996, HILLEY has been employed as 

Senior Advisor to the President and Director of Legislative 

Affairs with offices on the second floor of the White House, West 

Wi'ng, telephone number-. HILLEY has no pager or cell 

phone since he is resigning from this position effective February 

20, 1998, and both have been returned. HILLEY's successor is 

LARRY STEIN. 

Effective February 23, 1998, HILLEY will be employed as 

Executive Vice President, National Association of Securities 

Dealers, 1735 K Street, N.W., Washington, D-C., telephone 202- 

728-8100. 

HILLEY does not recall ever meeting MONICA LEWINSKY or 

having a personal conversation with LEWINSKY. HILLEY is certain 

that he must have seen LEWINSKY at office staff meetings or 

elsewhere in the West Wing since HILLEY recogngzed LEWINSKY as 

someone he had seen in the White House when LEWINSKY's photograph 

appeared in the news. 

HILLEY was aware that LEWINSKY and - made 

up the Congressional Correspondence Section of Legislative 

Affairs. A couple of months after HILLEY assumed the position of 

Director, TIM KEATING, the Staff Director, came to HILLEY and 

informed HILLEY there was a complaint that wand LEWINSKY 

had taken a large volume of mail to another office and demanded 

that office prepare immediate responses. It was obvious that 

neither-nor LEWINSKY were doing their job because of the 

large volume of unanswered mail; some of the mail was in excess 

of six months old. 

Investigation on 2/U/98 at Washington, D.C. File I 29D-LR-35063 

SA 

by CI Date dictated 2/12/g: 
1428 

29D-LR-35063 

Contmuaccn of OK-302 of JOHN LEE HILLEY ,On 2/‘11/‘98 ,Page 2 

HILLEY instructed KEATING to "take care of it" ar$i to 

"run the traps." HILLEY explained the use of the phrases "take 

care of it" and "run the traps" 

the people "upstairs," i.e., 

as meaning for KEATING to contact 

EVELYN LIEBERMANN, who HILLEY 

understood to be in charge of personnel and operations, to make 

sure the proper procedures were followed to move both _ and 

LEWINSKY out of Congressional Correspondence. HILLEY did not 

personally speak with LIEBERMANN about the matter but HILLEY felt 

sure that KEATING did. 

HILLEY was not aware of any other reason for the 

termination of Band LEWINSKY. HILLEY was not aware, at the 

time, of any rumors or gossip that LEWINSKY was having a sexual 

affair with anyone in the White House. HILLEY has never seen 

LEWINSKY in the presen$e of the President or in the vicinity of 

the Oval Office. 

HILLEY has not seen LEWINSKY in the White House since 

LEWINSKY's termination. 

HILLEY recalled only one conversation with KEATING 

after LEWINSKY's termination. This conversation occurred on a 

Tuesday night,.possibly January 20, 1998, just after the story 

broke in the news. Both HILLEY and KEATING attended a goingaway party for HILLEY and four other departing employees of 

Legislative Affairs. HILLEY and KEATING had a short conversation 

about LEWINSKY and the circumstances under which LEWINSKY left 

Legislative Affairs. 

HILLEY also recalled a conversation Gith JOHN PODESTA 

which occurred sometime between one and three months ago. 

PODESTA stopped HILLEY in the hallway outside the Chief of 

Staff's Office and asked HILLEY if LEWINSKY had worked for 

HILLEY. When HILLEY responded in the affirmative, PODESTA asked 

HILLEY if HILLEY would be willing to write a letter of 

recommendation for LEWINSKY. HILLEY agreed to write a 

recommendation letter for LEWINSKY since it"ti&??office practice 

to write letters for all former employees of Legislative Affairs. 

HILLEY ex,plq&qed to PODESTA that due to the less than favorable 

circumstances of LEWINSKY's leaving Legislative Affairs, the 

letter would have to be "generic," confirming LEWINSKY's 

employment and dates. PODESTA indicated that PODESTA would get 

back to%HILLEY on.the matoter, but to date has not done so. 
1429 

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

29D-LR-35063 

Continuation of OK-302 of JOtiN LEE HILLEY .on 2/11/98 ,page 2 

HILLEY was not aware that his name had been given to 

any prospective employers as a reference for LEWINSKY and HILLEY 

has not been contacted by anyone regarding possible employment of 

LEWINSKY. 

The above ila.Frr%-i kar;l r.nn..-bYr.=+: ,-.-m . . . . CL Vnnm-rrr” 

UL.3L.L A.ULU b”II” CL JQLIU113 WlLll AJafil .LLYb and 

PODESTA are the only conversations that HILLEY has had with 

anyone regarding LEWINSKY's employment with Legislative ABXL~s. 

HILLEY is slightly acquainted with VERNON JORDAN and 

has played golf with JORDAN on one occasion. HILLEY has not 

talked to JORDAN about LEWINSKY. 

HILLEY has not been contacted by anyone prior to the 

interview today and HILLEY has not discussed LEWINSKY with anyone 

except the attorney representing PODESTA. PODESTA's attorney 

recently telephoned HILLEY and asked questions abcut the hallway 

conversation between HILLEY and PODESTA. 
1430 
1431 

1 

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In re: 3 

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3rd ‘ Consrit”tlan, Y.Y. 

*a,hingron, D.C. 20001 8 

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Dopury 1n*.pen*enr counsel 

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MARY ANNE YlRT" 

JAMEscRAnE 

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1 Q All right We are here in a federal grand jury 

2 impaneled here in the United States District Court in the 

3 District of Columbia investigating possible violations oj 

4 federal criminal law, in particular, perjury, obstruction of 

5 justice, subornation of perjury and witness tampering. 

6 We are here pursuant to a jurisdictional grant fron 

7 rhe United Stares Court of Appeals for the D.C. Circ& and 

8 we are in par&d% iJWestiga+g those criminal allegations 

9 I just mentioned perjury, subornatioo of perjury, et Qtaa, 

D in relation to the civil lawsuit Paula C. Jones v. William 

1 Jefferson Clinton. 

2 Is it clear to you what we are investigating? 

3 A Yes, ii is. 

4 Q All right As we tell all witnesses before 

5 the grand jury, you have a right and a privilege against 

6 self-incrimination, meaning that if you feel that a truthful 

7 ans~~ ta a question would tend to incriminate you, you-do 

8 not have to answer it. Is that clear to you? 

9 A That is clear. 

0 Q As you know, if you have retained counsel, your 

1 counsel may not be pnsart with you in tk courlmom. You do 

2 have uwkJ hese today, do you JM? 

3 A I do. Yes, I do. 

4 Q And what was his name? 

5 A His name is Steve SZ.ivack. 

n re: Grand Jury Proceedings Multi-Panew Mav 19. 1998 

Page 3 

PROCEEDlNGS 

Whereupon, 

JOHN LEE HILLEY 

was called as a witness and, after having been duly sworn by 

the Forcperson of the Grand Jury, was examined and test&x 

as follows: 

EXAMINATION 

BY htR_ CRANE: 

Q Mr. Hilley, my name is Jim Crane. I met you 

outside briefly in the hallway. 

A Right. 

Q I’m an Associate independent Counsel. Here at my 

right is Mr. Sol Wise&erg, also with the Independent 

Counsel’s office. His title is Deputy. 

Obviously, this is the court reporter; the 

foreperson has just sworn you in. A grand juror is to her 

immediate left and the other grand jurors sit in the jury box 

and in the seats there out in the audience. 

Before we start asking you some factual question: 

I’ll just go over some of your I-@~& and responsibilities as 

a grand juror, which we do with all witnesses. This is not 

targeted at you in particular. 

But before I do that, will you state your full name 

and spell your last name for the court reporter? 

A John Lee Hilley, H-i-l-l-e-y. 

Page 1 - Page 4 
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1 re: Grand Jury Procdings Multi-Page n.4 May W,1998 

Page 5 I Page 7 

1 Q S-p-i-v-a-k? I Security Dealers here in Washington, D.C. 

2 4 I t_h_i& it’s S-p-i-v-a-c-k -- c or k. 2 Q All right. And that is a Private organization: is 

3 Q All right. We will check that and confirm the 3 it not? 

spelling later. 4 A That’s correct. ( 

4 

5 You understand that if you feel the need you will 5 Q And what is your title there? 

6 bc given a reasonable opportunity to consult with your 6 A I am Executive Vice President for Strategic 

7 attome y? i Development. 

8 A Right. 8 Q All right And, just generally, what do you do as 

9 Q Anything that you or any witness says here in the P Vice President for Strategic Development? 

0 grand jury can be used against you in a subsequent legal 1 0 A I deal with a whole variety of issues, working witl 

i ______.X:-- pr_lllr,y. 17,. ..^.. ..,,&,,+“..A *h-,*3 ! I *La ni.n:-.. A.c #ha WAflx c.l.m.* whrr cu.,. h,r.4.w.cr ,.,..A&. a)_ U” yuu l.LII”c.IOL‘aLILl UII1LL 1 “,b ~L,aaA*‘saLI “I Uh I.-Y, CUJVYC n..... VW “-*L- pm&* ‘\1 

2 A I do. Yes. I t how we plan for those and how we implement those. 

3 Q And you understand, of course, that you are under 1 3 Q All right. And before you worked at NASD or it’s 

4 oath and you must tell the truth. I 4 commonly called NASDAQ, is that conect? 

5 A Sure. OfcouM. 1 5 A Well, NASD, which I work for, is the parent company 

6 Q All right. There are several categories of t 6 of which_NAsDAQ isthe stock market, which is part of our 

7 individuals that appear before a grand jury. The fti is a I 7 affiliation Yes. So technically I work for NASD, but w 

8 target You are not a target. A target is defined as a 1 8 are the parent of the NASDAQ stock market_ 

9 person whom the prosecutor or the grand jury has substantial I 9 Q I see. And prior to working at NASD, you were 

0 evidence iinking him or her to t.he commission of a crime. ir empioyed ~~ ~ .~~~~ ‘n’~~~ Is iii~~ ~~~~ 

I And, as I said, you are not a target I A That’s cmfeCt_ 

2 The second category is defined very broadly and ii 2 Q And what w your position and whti were tk dates 

3 is called a subject. A subject is defined in the Department 3 of your employment there? 

4 of Justice grand jury manual as a person whose conduct is 4 A My position was officially Assistant to the 

5 within the scope of the grand jury’s investigation. You 5 President and Director of Legislative Affairs. 

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Page 6 Page: 

appear here today as a subject and as a witness. Is that 

clear to you? 

A Yes, it is. 

Q All right. Now, the oath of secrecy. The 

attorneys that appear here for the United States, 

Mr. Wise&erg and I, any of my colleagues in the Of&x 

of the Independent Counsel to whom we may share any 

port.& of the transcript of these proceedings are sworn to 

secrecy. Is that clear to you? 

A Sure, it is. 

Q All right Can you tell us the dates that you 

worked there in that _psition? 

A IwasempIoyedattheWhiteHousefortwoyears, 

from February of 1996 until Februaxy of this year, 1998 

Q All righ And before that, did you hold any otlxz 

position in the Clinton administration? 

A No,fdidnot. 

o _ The __-_ cau_r! ~nnrter_ =_____, the -._ ~..._~~ erand iurors are also .stvom .-_ 

to secrecy. You, on the other hand, are not sworn to 

secrecy. Is that clear? 

A Yes, it is. 

Q And you understand that you are free to talk to 

any person about the proceedings here today, including the 

questions that we ask yoy if you so choose. 

A Ido. . . 

Q However, you are not required to. 

A Okay. 

Q All right. With those introductory remarks, I 

till Start asking you some factual questions. 

Can you tell us where are you =dY employed, 

Sir? 

Q And did you work for a coxunitteeorforan 

individual? 

A Well, right before I came, I was working for the 

leader of the Senate Democrats, Senator Tom Daschle. 

Q All tight Now, what were your duties in 

Legislative Affairs? 

A I had overall responsibility for trying to effect 

working with Congrws the legislative program of tbc fe&zai 

government 

A Yes. I’m employed at the National Association of 

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Q And how many employees did you aupetvise? 

A I super&x! - it fluctuates a tiny bit, but 

approximately in this off&x around 24 people. 

Q Now, did Monica Lewinsky work for you in I 

PageS-Page8 

Divcrsificd Reporting Scticcs. Inc. (2021296-2929 
1433 

In rc: Grand luty Pruccxdings Multi-Page” May 19, 1998 

Page S 

I Legislative Affairs? 

2 A Yes. When I hpn in February of 1996, she was an 

3 employee at the Off& of Legislative Affairs and, in 

4 particular, the Office of Legislative Correspondence. 

s Q And who was her immediate supervisor in the Office 

6 of Legislative Correspondence? 

7 A Her immediate supervisor was the Chief of Staff 

P ” r\f “I the __ nffrrp _-_.- nf IePiclative Affabs~ a man named Tim I- --0----- 7 - --- 

9 Keating. 

IO Q Who hired Monica Lewinsky? 

11 A I couldn’t tell you. I assume it was my 

12 predecessor, but I don’t know that for a fact myself. 

13 Q All right. And your predecessor was? 

14 A br my position, my predecessor was a man named pat 

1s Griffm. 

16 Q So in February of 1996, when you came on the job, 

._ .I_ . _-_‘1__1_. _ _.^^ _,_“A.. _^,__._.I *I___‘) 17 Ms. LGWXIWK,’ Wiw aU=‘W~ WUjfi”yGU “*;IC: 

18 A That’s correct. 

19 Q Together with some 20-odd other people? 

20 A That’s correct. 

21 Q AU rig& Now, was Monica Lewinslcy terminated? 

22 A Well, there was a personnel action. How much -- I 

23 meau,Ican--thedirectanswer is, yes. she was transferred 

24 out of the Office of kegi&tive G~respondence when I was 

25 there. That’s correct. 

Page IC 

1 Q why? 

2 A I had been there, like I say, since February. 

3 My first notion that this was coming about was, I think, 

4 aboutamonthormonthandahaifafterIhadheentbem. 

5 Mr.Keatin&theChiefofStaff,cametomewitha 

6 recommendation, stating that the Office of Legislative 

7 Correspondence, which had two people assigned to it, one 

8 wasMs.Lzwiu&yaudtheothawasawoman~ 

9 m two of them were the Office of Legislative 

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Cmwtmndence r _______* 

Hecametomewitba rewmmendation and a report 

that, as he represented it to me, the office was not 

functioning properly and that both women were doing a 

insufficient job. 

My memory is fuzzy on this, but be had cited 

something like the mail had gotten really messed up witl 

tegard to something to do with OMB, that the mail was being 

done in a tardy fa$tion. I’m just paraphrasing, I don’t 

--L-- rL, r-“r* ,,...,-n+;.W. ,C;lUe‘Uuc, “6 Ei*oL4 W”“c4JO”“U. 

And he also represented to me at that time 

that both women, although for each it was a different 

representation, were basically not at their office, they 

were otherwise engaged, were not only doing a bad job, 

but I guess related to that were not present much at their 

duty stations, I guess is the way I would put it 

Page 11 

All of -- well, I’ll just let you go on. I think 

that was the report and Ihe recommm dation that came to me. 

Q All right. So would it be accurate to say they 

were fired? 

A Well, when -- yes. I mean, in the sense that they 

were no longer in his recommendation capable of serving in 

their present capacity. 

Q All right. And so both 

9 _ere fired. 

Monica Lewitlsky and_, 

0 A Well, the recommendation he came IO me with was the 

I following which is be said -- as I said, there were two 

2 pieces to this, each a little bit different story, but they 

3 were doing the job insufficiently and both were not Rally at 

4 the offi= doing their work and his recommendation to me, 

5 which he conveyed to me in a meeting, was that they be 

6 transferred, I think is the word he used. And so I‘m jus 

? c&., .r anarr 4L... I “ylrllj w IGIIGGL “LPL 

8 Q All right Where wasIIII) that she was not at 

9 her work station? 

:O A Well, let me just say one thing in general. I bad 

:I virtually no contact with either woman and every action I 

2 took and every recollection I have here today is based OI 

3 representations that were made to me. 

4 BY MR. WISENBERG: 

‘5 Q By Mr. Keating? 

Page 1: 

1 A By Mr. Keating. Yes. And so on anything, I havl 

2 no fust, direct-hand knowkdge of any of this, so what Pm 

3 recounting to you am representations that were made to me. 

4 Butthempmamtationthatwasma&tomeaho~ 

5 was that she had been phoning in sick for a period of time, 

6 but then there arrived a point where she was simply not tbue 

7 and not phoning in sick, was the gist of what was represented 

8 tomeabou~ 

9 BYMELCRANE: 

0 Q So would it be fair to till that unauthorized sick 

J leave or unauthorized leave? 

2 A I don’t mmemher anyone char&&zing it that way. 

3 Again, the case was represented to me that she was simply no 

4 at her position doing the job. I don’t know bow you’d 

5 categoric that, but that was the representation. 

6 Q Okay. Well, was she within the White House or the 

7 Old Executive Office Building or was she simply at home? 

8 A Again, 1 don’t know. When ic was told me, she 

n ..,rml+ rt La ,.F&TM r J-l, --h.WT L.L, r-t,4 .+- *L.+ 7 w-1 L a& IA4 “~IILC. I UVU L Lclllc.zLIuu -s UJLU WLUG LUL 

o speculation was that she was, if such was known. 

1 Q Okay. Did anyone ever tell yaw ;S 

2 not at her office* but rather in the White House mess, 

3 something to that effect? 

.4 A No. I don’t remember anyrepresentation of such 

:S detail. 

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!nit&_na D in _._ u-mz _-...- nnrtinn r _... -._ of the WIG& ...~_ Hr~rcp __-‘___ nr _.ttr . ..- XV&& 

House complex? 

A This is_ 

Q Ms.- 

A No. Ag&, the only representation that I recall 

was about that she had been taking sick leave but then was 

just -- I think not showing up at all and I don’t know where 

and it wasn’t represented to me what s’he was doi% and so 

there was no representation that she was doing any particular 

thing with her time. 

Q All right Now, with regard to Monica Lewinsky, 

what was she doing? What were the reasons she was 

terminated? 

A W&I, again, in the case of both women, the 

representation was that they we= doing an insuffjcient 

job at actually making sure the mail got answered in a 

timely fashion and it was furthermore represented to me 

that Ms. Lewinsky, and this is why I said it was a 

different representation than Fofilll), was wandering 

around. 

Q Okay. And how would you describe that? What do 

you mean, wandering around? 

A Well, it means to me not being there doing her job 

And, again, there wasn’t any specific -- it included 

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I wandering around the White House, is the one thing I 

1 remember, but beyond that, I really don’t remember any 

f destinations of her wandering, other than that she was 

I wandering around and wandering ammd the White. House. 

5 Q Where exactly was her office, the office of 

5 Legislative Gzm-espondence? 

1 A The office of Legislative &-respondence is in the 

I J%tWingoftheWhiteI-$usc. AsyouLookattheTrearwy 

I Building, down that haII in the East Wing, it’s on the 

t left-hand side. 

Q All right. What else? Did you find out that she 

! was doing anything else in particuhu? 

i A I’m sorry, who was that? 

I Q With reference to Monica Lewinsky, was then any 

i other reason for which She was terminated or transferred? 

i A None at all was represented to me. No. The two 

I representations with regard to her, that she was doing an 

I inadequate job at the mail position and that she was away 

+ from her duty station or desk or office or whateva you want 

3 to calf it and was wandering around. 

I Q Did you ever meet Monica Lewinsky? 

2 A I never recall actually -- I must have at some 

3 point. I~~~~~~~of~butI~~Irn~ 

* have because she must have attended some staff meetings in 

C rhr mnnrh anA z, half fir uihr.t,wpr st thr hpninnino A.4 .Irr. 

, “.” . ..” ,.... _..* . . . ..L. “a ,Y..l_.“1 . . “.V LlrgL.‘S,L’++ r),.U u1.s.J 

I A That was a young m,a” pamcd Chris Walker. 

2 * hfR_ WTSENBERG: I%% ioti mind if I intempt? 

3 MX.CRANE: No,goahead. 

4 BY MR. WISENBERO: 

5 Q YousaidthatMr.Keatingometoyouamonthora 

5 mon~~dah~~~u~~~job. 

I A I think that’s $@%ct. I’m gueSSin& 

3 Q In other words, you can’t pinpoint it. 

? A No, 1 can’t 

I Q AlI right. It could have b&en a little longer, it 

I could have been a little before then? 

> A Yes, it c&d have been. 

i Q Okay. Wouid you have any writings or notes that 

I you took that would - or a calendar that could pinpoint the 

i date he actuaIIy came by and told you about this? 

i A I don’t No. I remember the meeting thoq& that 

r becameromyoftke. MyofEceisintbeWestWingoftbe 

L White. House and so it’s - our office, Iike mcst, a few 

3 peop!eareintbeWestWiagllndmostpbopk~othapIaccs 

3 But I do rememberhimcamingandinabouta 

1 two-minutcc47nversationmakingavrrbalreporttomofthir 

2 andIremmberwhatItoldhim,whichisIwasnewaadI 

3 said, based on his representation, I said, “WC& take &. , 

Divcrsificd Rcuorting Services. Inc. C?,fl3\ 70c-~wm 

May 19,1998 

Page 15 

I I did -- when this stuff broke in the pnxs, after I had - 

2 hpr nirtwrp in th= nwnm- 1 r~rnoni7fvi h-v fw.= r’---- 

--_ -it: =-= 

-a, A ‘.cv.,~..‘-Y..“. .“W. Yes. so , 

3 that could onl) happen if I had met her. I don’t have a f 

Y J recollection, but I suppose she attended some staff meetings. 

5 Q And what about _ Did you ever meet 

6 her? 

7 A I must have also. And, again, I’d say very similar 

8 circus. I’m sum she must have attended some staff 

9 meetings very eariy on during that period. Yes. 

Q And how long a period of time were you there, were 

T you- and Monica Lcwinsky’s supavisor? How 

2 many weeks or months? 

3 A Well, from when I came, which was in February, 

4 until they left, which as I’ve read the press accounts now 

5 lately. it said something -- my reatlk&m is something in 

6 April, I -&ink, is when they Iefi the office. 

7 Now. I would have known when that was at the time, 

8 soI’msun:itwasreportedtomewbentheydidkavebecause 

9 the person who took the place in the Office of Legislative 

0 G~~~pondcncc was my pa-sonal administrative assistant who I 

I had inherited from the previous person holding my position. 

2 BY MR. WISENBERG: 

3 Q Who was that? 

4 A That was - the person? 

5 Q Yes. 

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‘been the iieputy Chici of Staff, Ms. Eveiyn iie’berman. 

BY MR. CRANE: 

Q And I believe that you were interviewed by an ~8 

agent, actually a retired FBI agent. and then -- 

A By two. 

Q By two agents. 

A YeS. 

Q Okay. And I believe you may have used the term 

“run the traps”? 

A That’s cxxrect. Yes. And to see the proper 

authority because this is not a decision that I in my newness 

and WI undastandiry3 the opaationo of the White House would 

have - I woutdn’t know how to effect it myself, to tell you 

thetruth. 

Q All right. During your time as director -- your 

title was Director of Legislative Affairs? 

A %t’S CQmt 

Q Did you have occasion to terminate or transfer 

under unhappy circumstances any other employees? 

A No, I don‘t remember any others that were 

transferi& under unhappy circumstances -- is that the phrase 

you used_ unhappy circumstances? 

Q tightA No. There were a lot of transfers as people 

changed jobs but, no, nothing of this type. 

Page I8 

1 Q No other transfers for poor job performance? 

2 A NotthatIrecallataU. 

3 Q On& Monica Lewinsky and-, 

4 A ThatiSmItXt. 

5 MR. WISENBERG: Can I ask a question? 

5 MR. CRANE: Yes, jump in. 

7 BY MR. WISE?NBERG: 

9 Q Didyouheary and this question goes to before, 

? during and after the transfer of these two employees and if 

1 you need to break it down you can, and I‘m not including -- 

I’m not including press reports since this became a public 

issue. 

~~~~~~~~~~~~~~ 

hear about any r&&ionship betwezn Monica and President 

Clinton? 

A Now, we’re exciuding anything that may have come 

out in the press siace January, correct? 

Q Yes. 

A None. 

Q ~~ri&t. 

A Again, the fmt I knew about the representation of 

ina*uatc pufoImallcc waswbmTimcametomcandthtcwas 

no part of that represented it was to do with a relationship 

and subsequently to that, there was not. 

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The first i heard of the reiationship, and i ” 

told the agents this, the first I heard of the alleged 

relationship or the thought that there was one U-S at a 

going away party which was acridly my gomg away parq x:tb 

other people ths January and I learned of it, &XX&, th 

night before, 1 read abour it%n the paper the following by. 

Q Who did you hear it from? 

A I heard that from Mr. Kenting. 

Q What did he tell you? 

A Mr. Keating - this was a party of our group. our 

Legislative Affairs group, like I said, during a going away 

partyandhe~uptomeandherep~ntzdtom,toldm 

that he had been called by the press and then he recouati to 

me what he had told the press. 

And he told the press that - well, they, of 

course, had told him that there’s this aiiegation, that’s the 

whole context of all this, but he told me that he told the 

press that both Ms. Lzwinsky and-had left 

basically because of -- you know, the same representation 

that he made to mc back in. you know, early 1996. and hc said 

he had told that to the press and that’s how I found out 

about it. And that was basically it. 

BY MR. CRANE: 

Q Did you ever have any discussions with Evelyn 

Lieberman about the reasons for Monica Lewinsky’s 

termination? 

Page 2( 

A Well, with regard to Ms. Lieberman, I knew that 

Tim-thatwastbepersonhewasgoingtotalktoaboutthis 

andheinformedmofthatandthatwastheright~to 

do. 

I just have talked to - you know, I imagine, I 

don’t know think it’s must, but I can imagine that I talkal 

to Evelyn about this knowing Tim was handling it, but 1 

didn’t become involved. In other words, I knew we wcrr botl 

awarcofit. ~d~~~d~~~~~w~r~ 

brought this to me and when they ultimately departed. .&nd 

then -- 

Q Okay. Let’s focus on that a minute. You had 

a meeting with Evelyn Lieberman after Tii Keating a to 

you? 

A No, I don’t recall a specific meeting, but it’s 

. . . *... -; possible. wnat 1 m saying is that I muid have ta-&ed to ha 

about this, but this is in the period between Tii bringing it 

to me and them departing. 

I don’t recall a meeting, but I don’t want to say 

that I didn’t because it would have been plausible ,md 

natural that ive would have said something to each otlxr in 

the hall about it. 

MR. WISENESERG: Can I gd back for just a mnd? 

MR. CRANE: Yes. 
1436 

In re: Grand Jury Proceedings Multi-PZt.gCTM 

Page 21 

1 BY MR. WLSENBERG: 

2 Q I want to make something clear about this with a 

3 global question I asked, which is what, if any, rumors did 

4 you hear about any kind of improper relationship between 

s Monica Lzwinsky and the President before, during and after 

6 her transfer. I want to make it clear to you that I don’t 

7 mean relationship literally, like the allegations since this 

8 has become public that there was a specific kind of 

9 relationship. 

0 I mean in the broadest sense that she was spendirq 

I too much time around him, that they were giving each other 

2 eyes, that she was just simply near the Oval Off& too much. 

3 Do you understand I mean it in its broadest sense? 

4 A We& I think the only thing that could fit that is 

5 what I’ve already said, which is the representation that she 

6 was walking around the White House. 

7 Now, that’s how it was represented to me, but there 

8 was no representation that that involved a contact with the 

9 President 

0 Q Well, she worked in the White House, though. 

1 A Sure. 

2 Q what would be unusual about her walking around in 

:L- _L_ ~..__,._J IL__‘) 

May 19,1998 

Page 23 

3 the White House lr sue worlGXl UFzel 

4 A She should have been at her desk doing her job, as 

s it was represented to me. 

Page 2i 

1 Q It wasn’t even as specific as she’s in the West 

2 Wing? She’s in the West Wing too much? 

3 A It could have been, I mean: I took it to mean.the 

4 whoIe White House. Imean, understand that because our 

5 office is separated, one in the East Wing of the White Hous: 

6 and one in the West Wing, that there is - you have to 

7 basieallypassthroughtheWhiteHouse,alIaspectsofthe 

8 White House, including the West Wig, to go between our 

9 offices. 

0 -___- ^_ .__ BY M.K. CKANK 

1 Q And when you say “our offices,” you mean the 

2 offices of Legislative Affairs? 

3 A Yes. In the West Wing. Yes. 

I Q Okay. So your office, is in the West Wing? 

s A Yes, that’s correct. 

5 Q And Monica’s and- is in the East 

I Wing? 

3 A That’s WIT&... 

> BY MR. WISENBERG: 

1 Q WbenyousayitcouldhavebeeqItookittomean 

I tbcwbokwhitcHousc,doyoumcaninothawordsyoudon’t 

1 know exactly what’s in Keating’s mind, but the way that you 

1 interpreted it was she’s simply spending too much time 

4 wandaing around the who& white House as opposed to being at 

5 her desk? 

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A But 1 would also -- that plus I &so believe she 

was wandering around the West Wing as well. 

Q All right. You just kind of got that from the 

representation. ( 

A That’s correct. Yes. I mean, I don’t know how you 

couldn’t be - a part of that couldn’t be wandering around 

the West Wing, given the logistics of the way the offices 

were set up. 

Q Okay. He didn’t say to you “She’s around the Oval 

Office too much”? 

A I do not remember that representation. No. 

MR. WSENBERG: Okay. I’m son-y. Go ahead. 

BY MR. CRANE: 

Q All right. We were taIking generaIly about your 

conversations or meetings with Evelyn Lieberman? 

A yes. 

Q About the issue of Monica Lewin&y’s tenninaticnr? 

A Yes. b. uU+pp 

Q Can you tell us what meetings and what 

conversations you had with her? 

A Okay. Well, when I testified to the agents, I told 

them, and I hope I’m repeating it very closely, I didn’t take 

-^a^” T I.,., _^ ..^drn ,C*hn, ........a-~&- “_ ,r- ,&.L” ‘l”Lc3,1 ,,avs II” U”&J “1 “‘,a, cullrGl-u”lq Jv 1 1” U”llrlj 

everything out of memory, there was one conversation with 

Evelyn that - I’m sorry, then was a meeting with Evelyn 

Page 

1 that I did not recall that - 

2 Q What & you mean when you say YOU did not recall? 

3 A Okay. When I testified - I’m sorry! what’s the 

4 word? 

5 Q Interviewed by or spoke - 

6 A Okay. WbeaIspokewiththeagans,andyouknow 

7 betterthan1it’slike_Ithinkitwasamonthandaha! 

8 orsomcthingago* 

9 MR. WISBNBERG: February 11,1998. 

0 -_.. ..--“^ Al___. ,x*_1 __,__ .._zrti rL_ ~~ __ IIIJZ w1LpIIzxi: “Kay. r*aoIs~KGmm--su 

1 itwaslonger&anI-okay. WbenIqokewitbtbem,Itold 

2 them absolutely everything that I could nooIlect about that, 

3 but in this intervening period, I have learned of the 

4 existence of a document that connected in my mind in my 

5 recollection, the fact that - this is quite a bit later - I 

6 hadameetin&~ll,notameetingaboutthisbutameeting 

7 with Evelyn that led to the production of this document 

8 BY MRCRANB: 

9 Q Okay. How did you learn in the last six weeks or 

o so of the existence of this certain document? 

1 A Okay. I received an unsolicited call from the 

2 White House Counsel’s Office -- 

3 BY MR. WISENBERG: 

4 Q Who? 

5 A It was a woman. it’s nobody I knew. and I don’t 

Page 2 I - Page 24 

Diversified Reporting Sct-viccs. Inc. (202) 296-2929 
1437 

In I-c: Grand Jury Procaxiinns 

1 red her name. The only woman 1 know there was Cheryl 

2 Mills and it was not her. 

Multi-PageTM 

Page 2 Page 27 

( 

3 Q If we gave you the name, do you think you might 

4 remember it? 

5 A If I had a list, I could try to pick it out. 

6 Q Could it be Shelly Peterson or Michelle Peterson? 

7 A That doesn’t ring -- is there somebody with a V ii 

8 her name or something like that? 

9 Q There‘s a Sally Paxton. Okay. We’ll get all the 

0 names. 

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know, otherwise engaged, away from their duty stafon. 

Q All right. Let me just interrupt a minute. 

Did Ibe attorney from whik House Counrcl’s Office send you a 

copy of the memo? 

A No. 

Q And have you -- 

A I didn’t ask for it and they didn’t offer it. 

Q AU right. And was your attorney ever able to get 

a copy of it for you? 

1 A Okay. Yes. I don’t know if I can -- I don’t 

2 recall what it is, but I know it wasn’t Cheryl Mills. She’s 

3 the only person I actually ever -- well, that I know that : 

4 met there who was a woman. 

5 So this person actually left a message for me, I 

6 think on my voice mail, to call me back. And so I -- wr 

7 traded calls a couple times and then when I finally reached 

8 her, abe said, “Are you aware of a memo conczming the Offic 

9 of Legislative Gxrespondence?” And I said, “No, I am not.” 

D Andtbenshereadrneabriefmemoandtbenuponthe 

1 readingofit,becauseofthecontart,thatitwasad~ 

2 toEvc~LicbamaoandjtwassignaibyaJohnsndgivcatbe 

3 mn~~IknewthatitwasindeedamemothatIhadwrinen. 

4 BY MR. CRANE: 

5 Q Okay. As best you recall, the way it was read to 

Page 26 

A Well, my attorney said that -- well, I’m trying to 

say this -- I’m not a lawyer, so I’m just trying to say this 

as precisely as I can, that with the exception of my lawyer, 

in preparation for this statement to you all, I have not seen 

it nor have I discussed it with anyone other than it having 

been read to me by the white House Counsel. 

-BY MR. WISENBERG: 

Q I think Mr. Crane had said something like -- 

referenced this phone call and said during the last six 

weeks. I guess if it was between your interview and now, it 

could actually more than six weeks, since your interview was 

February 1 Ith? 

A Yes. 

Q That’s March, April, May. 

A It could be. 

Q It could be 14. But what we want to know, one cs 

1 you by this unnamed pezson from the white House Counsel’s 

2 Office, what did that memo state? 

I A AI1 right That memo said - it was about the 

I Off% of Legislative cOrrespon&nce and it said -- it was a 

5 brie% memo and it said that - it talked about things that 

5 hadbeendone-getmydatesstraight-thismemowas 

r writtenlikeintbefaIIof1996beeausetbiswastbeperiod 

t inwhich~P;tndtawasltavingastheChiefofStaffanda 

P new Chief of St& &going to be coming in and Evelyn had 

1 beenaskedtobetbetmnsitionrxn&inat0randsosbebad 

I met with the heads of aU offices, as I understand it, at 

! leastshemetwithmc,andaskedmetoproduceamcmoabour 

I events - admir&trative events in the office that had 

4 oceurredthatyearandthatwasthegenesisoftttis 

Page 21 

: the things we want to know is when did you get this call? 

! A All right. The markers that I’m absoJuteJy certain 

1 arethatbec.auseIwasootawareofitattbetimethatIsaw 

I the FBI agents and now, those NIX the only truly definitive 

i things. IfIhadtoguess,IwouIdsay-andthisisa 

; guess-Iwouldputitatbetwecnfourandsixweeks~o, 

something like that. It was -- I’m just guessing. 

I Q Clearly bedbe you were subpoenaed. 

’ A EIeforeIwassubpoenaed 

0 Q Okay. And is there anything - 

1 A Oh, no. Wait a minute - yes. I was just 

2 subpoenaed, what, last week? 

memorandum. 

MR. WISENBERG: I think so. 

MR. CRANEZ Right. Within the past two weeks. 

THE WITNESS: Yes. It was before I was subpoeaaed. 

I am now rec0nstndng becauhe 1 could not 

remember the memo at all and did n0t -- so, anyway, I’m 

reuxistructing this. 

So I wrote a memo basically that said the 

things that were the issues in the Office of Legislative 

Correspondence, it spoke directly to the issue ofand Ms. Iewinsky, it said basically - using shorthand, it 

represented -- I represented the facts of the situation as 

they were represented t0 me about their departure; namely, 

that they weren’t doing a good job and that they were, you 

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BY h4R. WISENBERG: 

Okay. So you think between four and six weeks. 

I think so. Definitely since the FBI thing. 

MR. WISENBERG: That’s all I have. 

BY MR. CRANE: 

Did you have an attorney -- did you already have, 

3 your own attorney at the time the White House Counsel’s 

4 Office called you? 

.5 A No. I only hired my attorney who 1 can’t quite 

Pace 25 - Pa!J!??R 
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11 I re: Grand Jurv Proceedings 

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Page 25 

spe!l h:s name in the last few days, since I got my subpoena. 

BY MR. WISENESERG: 

Page31’ 

A Yes. 

Q But I was just asking not what you discussed wit_h 

Q .\nd when you spoke to the agents, you didrr’t have a 

lawyer present. 

A That’s correct. But I just in response, I think I 

tried to the best of my ability to tell -- I told them 

evepthing that I knew at that time and the only nrx piece of 

information that I did not recall was the existence of thi 

memorandum. So I think they should parallel each other. 

BYh4R.CuANE: 

him, but whether or not you personally have laid your eyes 

that memo since you composed it and you don’t even runenba ( 

that. 

A You mean other than with my attorney? 

MR. CRANE: No. We may have an attorney-client 

issue here. If you have seen something, we are entitled to 

ask you have you seen this document, have you sezn these m 

stickers. 

Q Was Monica Lewinsky andtermination a significant event in Legislative Affairs? 

.X1-11 TI- -..- :r ___^^ _:_:Lz___r c__ rL_ A we,,, 1 m surtz 11 W& slglllllCalll,“1 “Kin. In 

this area. again, I mean, I didn’t know the young women, I 

have no judgmental basis about what kind of people they are. 

All I was was acting on a representation that was made to me 

by the person in the office who was delegated with such 

responsibility. And so when Tim Keating came to me with a 

recommendation - 

Q Okay. My question is -- 

A I mean, I don’t want this to sound callous, but, 

you know, it was a personnel decision that the person in 

charge of them and should have known the facts of tbe case 

madetomeandassomeone several layers removed fnnn their 

oversight, I simply made that and it was about a two-minute 

Multi-Page” May 19, 1998 

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2 him? 

3 THE WITNESS: Why don’t you all? 

4 MR WISENE4ERG: We can do that. why don’t we take 

5 a very brief break 

We are not asking you about the substance of you 

private conversations with your attorney, which are 

. . ..rn.1_-2 l - L- __^_^_. -1:-r ~“‘IDIUtXUJ L” vc aLrorUG:y-clKzli. 

THE WITNESS: Okay. 

MR CRANE: But what Mr. Wise&erg is asking you is 

have yc?u seen this memo. 

THE WITNESS: Okay. I want to be completely 

coopetativc and open with you, okay? And not being a hyu, 

he has sort of told me one thing, you’re telling me another 

and so - 

MR WISENBERG: Would you like to go and speak with 

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Page 30 

involvement. But I’m sure it was a significant thing for the 

young women concerned. 

MR. WISE~TIERG: Pardon me for interrupting. 1 want 

to ask a technical question. I think this qualifies as 

te44inical. 

BY MR. WISENBERG: 

Q Have you &y seen a physical copy of this memo 

that you had forgotten about? 

A Well, again, I mean, you might want to talk to my 

@somey, but I have not sea it M discussed it with anyone 

with the possible exazption of my attorney. The memo to 

Evelyn. 

Q I’m not interested in your discussions with your 

attorney, but just whether or not you have seen it. 

A Well, I must have seen it when 1 wrote it. 

Q Right. Good point. 

A Yes. Although to this day I do not remember 

actually composing it, although I know it’s mine by the 

nature of the contents. 

Q Have you seen it since you’ve been informed by the 

White House about it? .: #: 

A Not by the White House. And that would have only 

been possible with my attorney and maybe you -- I mean, I’m 

not a lawyer and he said this is -- you know -- 

Q Attorney-client. 

Page! 

1 THE KXEE’ERSON: sure. 

2 ‘IHE WITNESS: Because I just don’t know how to 

3 respond, given I’ve gotten sort of two different things and I 

4 have no clue. 

5 MR WISENBERG: 1% never heard of two lawyers 

6 dkagreeingab~utanything. 

I (Laughter.) 

6 MR WISENBE& May the witness be briefly cxcuszd? 

9 ‘IHE POREPERSON: Absolutely. 

0 THE WrrNEssz Thank you 

I THE FOREPERSON: You’re welcome. 

2 (Witness excused. Witness recalled) 

3 MR. WISENBERG: Let the record reflect that the 

4 witness has reentered the grand jury room. 

5 Madam Foreperson, we have a quo- do we not? 

6 THE FOREPERSON: Yes, we do. 

7 MR WISENBERG: Any unauthorized pas0a.s pnsent in 

8 the grand jury room? 

9 THE F0REPERSCIN: No, sir. There are not. 

3 Mr. H%zy, you are stiIl under oath. 

1 THEwll?ms:Thankyou. 

2 BYhGLCRANE? 

3 Q Okay. Mr. Hi&y, before we took a break, 

I Mr. Wise&erg and I had asked you have you sen a copy of 

5 that memo that you wrote some time back in 1996 or 

Page 29 - Page 32 
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In rc: Grand Jurv Proce&in~s Multi-PweM Mav 19.1998 

Page 3: 

1 thereabouts. 

2 A Yes. My lawyer showed it to me. Other than 

3 writing it, that’s the only time I saw it_ 

4 Q All right. And that was in the last few weeks, 

5 I take it, or within the last few days? 

6 A Few days. 

7 Q Because you’ve only recently had an attorney? 

8 A Yes. 

9 MP ,-W ANC. nkav T I=+ m-e Chnw “n,, whl? I’m A..&._ bIY”.Y. V....J. -. -v . .._.. ,v.. 1 1.1 

0 label@ as Grand Jury Exhibit JLH-I and see if you can take 

1 a look at it. 

2 (Grand Jury Exhibit No. JLH-I ‘was 

3 marked for identification.) 

4 BY MR. CRANE: 

5 Q Have you had enough time? 

6 A Yes. 

7 Q IS that the memo that you wrote back in October - 

8 is it October Of 1996? 

9 A It says October 16, 1996. 

0 Q Okay. And that is the memo that you in fact wrote? 

I A WelI, again, I just want to stress, obviously 1 

2 would have told the agents about it if I had rememberedat 

3 thetim. Istilltothis&ydonot remember composing this 

4 memo, but judged by the content and it’s to Evelyn and it’s 

5 mv signature and the way it’s constructed. it is mine. Yes. 

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Okay. It is your signature there at the bottom? 

Yes, it is. 

It says only John. 

That’s me. 

AU right And you wrote this memo to Evelyn 

Lieherman. 

A That’ScOrrect. 

Q All right. No?, directing your attention to the 

_ ennrl _--_ fill1 _- narm-ranh - r---l-- 

A Right. 

Q What does that term “extracurricular activities” 

mean? 

A What that means is -- now, I don’t -- again, 

because I don’t recall composing this, I can’t explain why I 

chose the particular phrasing, I don’t remember choosing this 

particular phrasing, but what the content of this conveys is 

what I believed thn and still believe to this day is an 

accurate depiction of the facts as they wxaz represented to 

me by Mr. Keating about the reason for the transfer of both 

women, sd Ms. Lewiusky. 

Q All right. Let me just focus in on that. 

A sure. 

Q Would it be consistent with your recollection, 

then, that Mr. Keating used the term “extracurricular 

activities” and that you repeated it as you bad repeated his 

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description of Bnnd Monica I.ewi~~&~ 

activities? 

A I cannot recall him using that term. I don’t 

rernui~bcr exactly what the ta-m.s w’be. I do remember tbc two 

substantive parts of that., which is, again, they were not 

doing the job and that they were -- I’ve paraphrased this 

many ways, were otherwise engaged or -- again, not 

remembering writing this exact phrase, I know what I would 

mien hv it oiv- the r~nr~rmtcatinnr frnm Mr Y~=t;nn w,h;,A I.._. “J .% p..d. . ..v ..y.‘u....r^..“..~ ..“A., IV.., ..b.a.u* “IUbLI 

is that they were away from their station and not doing their 

1 job. But I can’t say that I remember him using that phrase 

2 withme. 

3 Q b you remember any other person using that phrase? 

4 A No, I don’t. 

5 Q Do you know of any other meaning for that phrase as 

6 it might commoniy be used? 

7 A Well, all phrases have -- yes. 1 mean, I was a 

8 professor, it means -- it can have positive or negative 

9 connotations. In this case, it is a negative connotation 

0 because of being absent from their work station. But it 

1 could be positive or negative, but I clearly meant it here in 

2 the nqative connotation. Aa& again, I’m using shorthand 

3 here because Evelyn, Ms. Lieberman, as I understood it, 

4 understood the facts as they were represented in this 

5 situation. 

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Q All right. And looking at the top of your memo, i 

says “Thanks for meeting yesterday.” 

A fight. 

Q And the memo, Grand Jury Exhibit No. 1 that 1% 

handed you is dated October 15th. 

AFGghL 

MR WTSEWBERG: JLH-I. 

MR_ CRA.Fk JLH-1. 

RY MR PRANE- - _ ..-.. _... I .-. 

Q Would it be a fair assumption that you must have 

had a ma%ing with Evelyn Lii on or about October 15th. 

A That’s correct. 

Q Okay. The previous day. 

A That’s what this implies. Sure. 

Q Allright. Andsodidsheuseonthemeetingon 

October 15th. did Ms. Liebennan use the term *extraeunicula 

activities”? 

A Again, I don’t recall her doing that and, to tell 

you the truth, I don’t recall us even discussing the issue of 

Ms. Lewinsky and w 

Q All right. 

A Bui what this also implies was she asked me to go 

do a brief memo about things slated to the Office of 

Legislative Correspondence_ 

Q Okay. And she in turn apparently was going to 

Page 33 - Paee 36 
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Ante her own memo from what you say in here, and I’n 

referring to the second sentence that says, “I wanted to 

follow up on a few points as you put your memo together.” 

A hhl-hmm. Right. 

Q Now, why was Evelyn Liebzrman writing a memo in 

which Monica Lewinsky’s extracurricular activities were an 

issue? 

A Well, I don’t know -- 1 neva saw whatever memo she 

may have composed, but, again, as I tried to indicate, Iet me 

go back to it, this was the period at which Leon Panetta was 

leaving and a new Chief of Staff was to be hired and Evelyn 

had been appointed the transition director for that. And so 

she had been tasked, I think, to sort of get ready and give 

information to whoever the new Chief of Staff would he about 

this. 

And so I think that was the context, was her 

transition part, but I don’t remember discussing this 

specifically in the meeting. And I don’t know what she wrote 

to who, to tell you the truth. 

Q All right. Do you believe - in particular, 

referring to the second bullet that refers to the 

extracurricular activities, do you believe you put that in 

there simply on your own or you wrote that paragraph, b&let 

number 2, in response to Evelyn Lieberman’s request that you 

need to summarize or memorialize Monica Lewinsky’s 

Page 38 

1 termination for the potential incoming Chief of Staff! 

2 A I don’t remember her prompting me to do any-thing 

3 specific in this memo. Like I say, I don’t remember 

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composing the memo, so it’s very bard for me to reconstruct 

this. I don’t have any recollection of her trying to guide i 

me about anything in this, but ckarly what it’s related to 

is there are several aspects, act&y, three major aspects 

tothememo. ~was~othermcmotbatwaspartofthiq 

you know - 

Q That you refer to in the second bullet where it I 

says “I bavc also cncloscd a brkf mano on our comcspondcncc II 

operation”? 12 

A That’s right. Well, as well as the division of 13 

responsibility, and then it refers to that we also had 14 

problems with the NSC, which is the National Security IS 

C&inciii and **“kite iiousc Gxrcsponciencc, which is a dirhali i6 

office than the legislative wrrespondence. 17 

So, actually, I-think there’s four point.9 in this 18 

memo that were made about the Office of Legislative 19 

Correspondence, one of which was about specifically_ 

I 

20 asked me to do, but by the cuntent of this memoIzndum, she 

1 _nd Ms. Lewinsky. 21 musthaveaskedme16writea~oabout~with~ar’ 

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,PagCR” May 19,1998 

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A That was my assumption, bzt I - that is just an .‘ 

assumption. I don’t think she ever totd me who was going to I 

see it, in what form. None of it was ever shared with me. 

This fell from my memory immediately and I don’t know what 

t 

became of any of this. 

Q All right. And you refer in tk second bullet to 

the NSC and Wtitc House Correspondence. 

A Right. 

Q NSC is -- 

A National Security Council. 

Q All right. 

A They have a wrrespondence operation, as does tht 

White House. ‘Ihere are sevd correspondence ofTices in the 

White House. 

Q And did you also supervise those? 

A Nb, I did not, Atthough just to give you the 

explanation, we handled congressional mail, principally, and 

so if them were a letter, for instance, from a congressnan 

about a national security matter, that woufd be routed to the 

NSC to formulate the letter and then be routed back through 

us. So it was a coordinated effort, but I did not supervise 

them. 

Q Okay. At the end of your memo, it says, 

“I appreciate your help. I will take the steps you 

suggested and then follow up with both you and Leon.” 

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A Mm-hmm. 

Page ! 

Q What were the steps that she suggested? She, 

Evelyn Liebexman. 

A Thiswasabout-eachofusaswecameinwere 

tIcingaskal,okny,whatkiIldofjobbavcyoubcendoiog,what 

~d~~offl~~~~~,~~~~of 

goals and how do you think your office could be more 

efficient. So it was &&ally getting to know what our work 

was and what we had done_ 

Andtbensofwasseekin~herguidaneeonhowI 

should proceed about my responsibilities and the performance 

ofmy offiaas,youknow,wwimtthroughthistramition 

ph~~d~~~efofS~~~~_ So&was 

preparing - gening her help in prepa@ for the ttansition 

as I confronted a new boss. 

Q Aiiright. AndmyquestiontoyouishowisIvionica 

Lewis&y’s termination relevant to the job the new Chief of 

Staff was going co do? yb j 

A WelI, again, I don’t remember exactly wbat Evelyn 

2 Q Okay. Is this accurate, that Ms. Lieberman as the 122 to the Office of Legislative Cornqondenoe. And, lik( 

5 transition coordinator for the new Chief of Staff who would 23 said, I mean, there am about four parts to this, so I doh _ 

4 reptace Leon Panetta was going to use your memo to brief or 24 recall -- you‘d have to ask her, to & honest with you -- 

5 to get the new Chief of Staff up to speed? 25 Q Letmejustinterrupt,ifIcan. Itseemstome 

Page 37 - Page 40 

Diversified RcuortinE Services, Inc. (2021296-2939 
1441 

In rc: Grand Jury Proccediogs Mull 

Page 41 

1 that the transfer or unhappy termination, termination or 

2 unhappy transfer of bionica Lewinsky and- wz 

3 probably irrelevant to the Chief of Staff of the President of 

4 the United States. Is that a fair assumption? 

5 A I can’t judge that. I know that when a person whc 

6 is my boss, tbe Deputy Chief of Staff, asks me just to write 

7 a memo -- and, again, I’m reconstructing this because I don’t 

8 nznanber writing it, asks me to write a memo about the Oft& 

9 of Legislative Affairs and the issues we face that year, I 

1 0 don’t say, “What are you going to use it for and who is this 

1 1 relevant for?” Et cetera, like that. That is not somethin] 

I 2 Ididatthetime. 

I 3 I simply responded to her request without being 

1 4 judgmental about what she wanted it for. And I’m just 

1 5 assuming that it had to do with the transition, but, again, 

I 6 I’d urge you to ask her. 

I 7 MR CRANE: Okay. Mr. Wisenberg, do you have some 

1 8 questions? 

1 9 h4R. MSENJ~ERG: Oh, yes. 

28 0BY MR. WISENBERG: 

2 1 Q “I have also enclosed a brief memo on our 

2 2 correspondence section. It was in bad shape when I came in.” 

2 3 Let’sstopthereforasecond “XtwasinbadsbapewbenI 

2 4 came in.” I don’t mean to be rude, but it almost sounds like 

2 5 a classic CYA, you know, it was already in bad shape, I 

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Page 42 

inherited a bad situation. Had Ms. Lieberman expressed her 

dissatisfaction to you with the correspondence section in 

this meeting that you had the previous day? 

A I don’t recall her having done that, but what 

this -- the bad shape, again, this is all reconstruction and 

it’s just guessing by the content of the memo, but I believe 

what it must have referred to was that shortly after I came 

in I did receive this representation from Mr. Keating that 

the Office of Legislative &rcsj~~~&~~cc was in bad shape and 

not performing appropriately and that was the basis upon 

which be came to me with tbe representation and I told him to 

run the traps and talk to Evelyn. 

He represented he was going to do that and so I 

think that is the wntcxt of how the office was - 

Q I’m not disagreeing with you that it was in bad 

shape, I’m just saying the fact that you would use the words 

“itwasinbadshapeWhenICamein”isWhatledmetoask 

you had she complained to you about the state of 

correspondence. 

A In this meeting? 

‘%%that I recall . No . 

Q All right. 

A In fact, I don’t remember us taIking about in this 

meeting the Office of l&slative Correspondence, but it must 

5-I May 19,1998 

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be the fact that she asked me for a letter about it, or I 

wouldn’t have produced it. 

; 

Q Let me ask you this. Your next line is, “We got i 

rid of h4onic3 and Jocie, not only l~~~u.se of ‘extracticular 

activities’ but because they couldn’t do the job.” 

A Right. 

Q It almost seems like -- you know, your first reason 

her\: is extracurricular activities. Not only did we get rid 

of them because of extracurricular activities, but by the 

way, they couldn’t do the job. They~ouldn’t do the job, it 

seems like it’s the secondary reason for getting rid of 

Monica and Jocie. Is that accurate? 

A Well, again, because I don’t remember writing thr 

memo and the exact use of words, but to this day, it seems 

to me that - you know, that it talks about both women not 

doing-the job and both, they, engaged in extracurricular 

activities. 

And I believe that although this is a shorthand 

way, it is consistent with and accurate to the representation 

that Mr. Keating made to me about the situation there, name:: 

that there was an insufficient job being done in the mail and 

each for a different reason neither was really at their 

station and were otherwise engaged_ 

Q So based on what Mr. Keating told you and based on 

the wording here and based on your memory, was the primq 

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reason their extracurricular activities, whatever they might 

Page 44 

be, was the primary nzason they were kicked out tkir 

“extracticular activities” and the szxondazy reason tha 

they weren’t doing the job to the optimum level? 

A ~lIcansaytoyouisthatwben~.I(otingcam 

tomewithhis lvXnmaI&tioa, he prsen&d lhem as nvo fact.9 

without - I don’t ever nzmember him saying one’s impost, 

one’s not. He brouj$t it to me as a related package and even 

now it seems to me they are related, namely, that they 

weren’t doing theii job and they were away from t&r 

station. ‘Ihat is what he represented to me and that’s what 

this conveys. 

Q Were the extracurricular activities, whatever they 

may be, whatever they were, were the extracurricular 

activities we11 known within Office of Legislative Affairs? 

A I don’t know. I mean, I was the new guy who had 

just come in, I had no ftrsthand experience with either o: 

tlwx: women. 7Ss was tk nzprscntation bar was ma& lo me 

and so I don’t know what others’ feelings were about its 

because I was not close to the situation at all. 

Q Because the reason 1 ask, one of the reasons that I 

ask is you doh’t even define extracurricufs act&ities. You 

bad a mating with Evelyn Lkbaman a$ you say kc got rid of 

them not only because of extracurricular activities, but they 

wuldn’t do the job. 

Diversified Rc~~orting Sticcs. h. f20?\ YML-~~~Q 
1442 

Q Mr. Hilley, have you ever heard the term I 

II I-C: Grand Jury Pnmxxi@y Multi-Pagem 

Page 45 , 

1 A Yes. Well, again, it refers to both women and, I 

2 again, I have no recollection of why I would use a*$%rtitilar 2 

3 phrase, but as I testified to the FBI agents, you know, ant d 3 

4 to you today, I spoke to them, or whatever the right word is, 4 

5 that it is -- what I meant was to recount for a situation 5 

6 that Evelyn was already aware of exactly the representation 6 

7 as I remembered it that Mr. Keating had made to me. 7 

8 BY MR. CRANE: ' 8 

9 Q So is it possible that that term, extracurricular 9 

0 _._r:..:t:_, __...a f,,-.m ,;thpr l2m4.m 1 ;~h-.,,,a, ,.a. Mr Tim ELLIVIUW, L.4uLI-G l‘"l,,t/LU,~‘ ti.s4,“ "‘CCICL“,LI1, ". ..". ,a-.* ! to 

1 Keating? I 1 

2 A I don’t recall them ever using that term, no. I 1 2 

3 don’t I don’t recall me choosing that term either. 1 3 

4 Q Any reason why you woutd have put it in quotation I 4 

5 marks? 1 5 

6 A Well, it was a shorthand way of indicating I 6 

7 some&& that Evelyn was already aware of. Sbc and Tii had 1 7 

8 dealt with this situation and, like I said, I had about a 1 8 

9 two-minute encounter with this situation, namely, approving 1 9 

10 his recommendation to go further upstairs. 2 ‘0 

!I Q All right. So is it fair to say that Evelyn 2 :1 

!2 Lie&man knows what you mean wh you say “extracurricular 2 :2 

3 activities”? 2 :3 

i4 A I can’t read her mind, but I know that she -- at 2 4 

is least it was represented to me and I believe it to be the 2 !5 

1 

I 

extracurricular activities to be used in feferenee to maybe 

some sexual activity? ! 

A As a generic proposition or as relating to this? 

Q My question is just have you ever heard that. 1 

won’t say generically or -- 

A I don’t remember -- I mean, I can imagine it being 

used that way, yes. I don’t bave a recollection of a person 

~rcino yv".b it 1- that I._. ursv '._J cne~ifirnllv "~V_""-"r,. 

Q With reference to Monica Lewinsky. 

A Oh, no. Not at all. 

Q But does it make sense to you when a man, for 

example, says that a young lady is engaged in 

“extracurricular activities” that that may have some sort of 

sexual innuendo in there? 

A Extramarital -- 

Q 1 didn’t mean to say eXtEim%ritd, 1 meant sex&. 

A No, I know. No. I’m just saying - I’m just going 

through words that would convey the concept that you have. I 

don’t know, since I don’t remember writing this, why 1 u& a 

pi&uiaf term. 

Q Okay. Let me just ask my question again. 

A SUIT. 

Q Wtienamanusesthetenn,amansayst.oyouthata ,.. 

Page 46 

1 case, that she knew the facts of this as it was representec 

2 to me, so I think that she would know what they are. 

3 MILWISENBERG: It's break time. 

4 MR. CRANE: Break time? 

5 MR. WISENBERG: It’s break time. 

6 How long? 

7 ?HE FOREPERSON: Fifteen minutes. 

8 MR. WISENBERG: -Okay. 

9 MR.CXWNE: Allright. 

0 hm. WISENBERG: We're going to take a 15minute 

I bizak and I Will come and get you when we have a quorum at 

2 about 3:O0. 

3 THE WITNESS: Okay. 

4 MR. WISEIWERG: May the witness be excused? 

5 THE FOREPERSON: Yes, he may. 

6 (Witness excused. Witness recalled.) 

7 MR. WISENBERG: tit the record reflect the witness 

8 has reentered the grand jury room. 

9 Madam Foreperson, do we have a quorum? 

0 THE FOREPERSON: Yes, we do. 

1 MR. WISENBERG: ibethefea~~y UnaUthOrkdpt~~Ons 

2px-fsent? 

3 THE FOREPERSON: No, the aren’t 

4 Mr. Hilley, you are still under oath. 

S THEWlTNESS: Thank you. 

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young Iady is invoIved in “extracurricular activities” does 

that suggest to you any sexual connotation? 

A No. Not zeally. 

BY MR. WISENBERG: 

Q Did you intend for it to have - 

AJURO? What doesitsnggest? 

THEWITNEW Inregardtothismemorandum,Ithink 

it’s very clear, agafn, I don’t remember writing this so I 

can’t say - but what I probably meant, I eutainly meant, it 

seemstome,wastoeonveythatwIiathadbeenreprcsentedto 

me,thattbey-Imean,thissaysthey,MonicaandJocie, 

it’s they, they couldn’t do the job. Monica and Jocie both 

had extracurricular activities. 

And so clearly there in this context what I’m 

refcrringtoiswhatIbelievetbe~resentationwasmadeto 

mebyMr.Keatin&~chisthatthey~awayfromtbeir 

duty stations, they were otherwise engaged, it was about 

they, the both of them. 

May 19,1998 

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And so, no, I would not single out this to mean 

anything other than that bemuse it’s about both of them and 

that’s the report that was given to me by Mr. Keating. 

BYMKCRANEl 

Q Okay. Let me just ask you a question. If the ’ 

akgation was that they went simply &ay from their duty 

station, why didn’t you just say Monica Lmhsky an_ I 

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1-e away from their duty stations period? 

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A Again, I don’t remember why I used the particulru 

term, but this is a shorthand for a matter that Evelyn 

already, I believed and do believe, knew the facts of -- 

BY MR WISENBERG: 

Q Indubitably, you say? 

A I do believe. 

Q You do believe -- 

A I do believe knew the facts of. And so, 

again, this is something that was based purely on a 

representation -- andletmejusttrytogotothe 

bottom line, which is I never observed -- as I testified 

to the FBI agent, I never observed and it was never 

represented to me by anyone, Mr. Keating or anyone, that 

either young lady was involved in any relationship of the 

type that has since been reported in the press. 

So I did not use this term in any other way than 

the representation that Mr. Keating has made to me, which I 

have tried to be clear about. 

Q You did not intend it to have any sexual context. 

A I did not intend it to have sexual context. I was 

completely unaware, as I have stated to the FBI and you, the 

first hint that I had that there was an allegation of 

sexuality to do with anything was the night before it hecame 

public in that conversation with Mr. Keating, reporting on a 

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umversaticmhehadhadwithtbepnzss. Iwasassurprised 

as anyone on this earth 

BY MR. CRANE: 

Q All right_ Did you tell the FBI agents that Monica 

LewinsQ and e involved in loitering or 

extracurricular activities or being away from their duty 

&w:aGns? 

A I probably used, as I have here today, a variety of 

characterizations to c&vcy the same content as it was 

represented to me, two components: they were doing an 

insufficient job and they were not at their offices doing the 

job and they were away othawise engaged. And the most 

detail I have for you-on that, as I’ve tried to say, but 1’11 

say it again, is in the case of Ms. Lewinsky, it was 

represmtedtometbatshewaswanderingaroundandinthe 

caseof~itwasrepresentedtomethatshehadbeen 

phoning in sick but now was completely missing without 

phoning in sick. -.. 

Q Okay. Are you confident that you relayed that 

information to the FBI when they interviewed you back in 

February? 

A I don’t bow. Again, I didn’t take notes or 

anything, but I tried to, both then and now, to completely 

convey the full extent of my know- about this. Maybe I’m 

Pagem May 19,1998 

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Page 51 

Q Did you tell the FBI about the second pan? of what 

Mr. Keating told you, not just that they weren’t doing 2 good 

job, not just that Monica L.ewinsky wasn’t doing a goxi job, 

but that Monica Lewinsky was wandering around the Utite 

House? 

A I think I did. Yes. 

Q So when you heard about the memo four to six u&s 

ago from the White House Counsel’s Office, I think yet 

testified earlier that it triggered a mLnory of your meeting 

with Evelyn Lieberman. 

A Right. 

Q But it didn’t trigger a newer or better memory of 

what Mr. Keating told you. 

A No. 

Q Qkay. No, it did not trigger -- 

A No. No. I tried to convey the content, the 

completely identical content to both you here today and the 

FBI people that I spoke to. 

Q In other words, it’s not -: I want to just make it 

clear for the record hecause we have a double negative here. 

You are saying that, no, the memo did not convey an exrra 

memory or a new manory with respect to Mr. Ksating because 

you had previously remembered that and reported it to the 

FBI. 

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A The best of my recollection is that Mr. Keating, 

andIrepresentedtotheFBI,that.thadcometomewitt 

this report and that it had been both aspects of that with 

regard to both women, with slightly different circumstanas 

as I explained. 

Q Whe.nthememowasreadtoyouby&bodyatthe 

White House Counsel’s Ollicq you didn’t all of a sudden hit 

your hzad and s;rp -- 

A No, Ididn’t. 

Q “Oh, that’s right, Mr. Keating also had told me 

this business about her beii away from the West Wing.” 

A No. No. When I - well, I was very surprised, 

you know, obviously, by this because I didn’t recollect it. 

And, in fact, when I got my first voice mail from this 

person, I returned a voice mail that said if I’ve made a 

mistake on my exit form, please leave a message so that I 

can correct that. 

That’s what I thought the content of what was - 

you know, that’s what 1 thought the call was about and I 

ieft a voice mail to that. AG then I got a call that asked 

me, as I’ve already said, did I rememherthismemoandIdid 

not. 

BY MR. CRANE:. 

Q How many times did you trade phone calls with the 

person from White House Counsel? 

-I 

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A’ I can’t recall. Maybe two -- two times. I left a 

voice mail. 

Q Did you save any af them? 

A I don’t know. I don’t save my voice mails, but, I 

mean, that could be checked. 

Q Did you save any documents that would have the name 

of the person who called you? 

A No. 

Q An e-mail, a phone slip? 

A No. No. 

Q Nothing like that? 

A Not that I know of. No. 

Q You have no way of knowing what that person’s name 

was? 

A Idon’trecallit. Imean,l’dbegladtocheck 

and try to find out. 

Multi-Pagem May 19,t998 \ 

3 Page 55 

I like to ask in regards to the number of days_ 

1 

2 was absent. I 

3 BY MR. MSEJ’SBERG: 

4 Q Actually, I had a question about -- My fust ( 

z question is do you know whether or not your depnnxxt or 

6 the Office of Legislative Affairs would have the backup 

7 documentation as to the number of days she was absent 

8 

9 A I don’t know, but someone in administration 

J 0 probably should know. 

I 1 Q Do you know why Monica Lewinsky when she gc 

1 2 transferred out basically got a promotion, number one - 

1 5 let’s ask that question first. She’s being transferred out 

1 4 because she screwed up, if you’ll pardon the vernacular, and 

1 5 yet she gets what’s clearly a promotioo, a nice posh job at 

1 6 the Pentagon. Do you know why? 

I 7 A %‘efl, 1 was not invoked ia that process and, 

I 8 again, to my recollection, I don’t think I knew where tither 

1 9 young woman had cndcd up bcforc this became public. I chink 

2 0 that’s the case. 

2 1 Again, I was involved with approximately-a 

2 2 two-minute conversation with Mr. Keating where he ma& the 

2 3 representations as I’ve recalled them here to you today. 

2 4 And, on that basis, I told him to take it to a person of 

2 5 higher authority in the White House. 

P*C 

1 After that point, it was out of my hands in terms 

2 ofehedispositionofwhatbcwncoftbttwoyouagwomcnin 

3 terms of where they coded up. 

4 AJUXOR: MayIask,asy&lookbackonallof 

5 this now, would you say that there is a possibility that 

I 6 you’vcbeenusedinpreparingthiskiadofa~ttso 

MR. WISJW’BERG: If you have any kind of docunxnt or 

information that could pinpoint either the name of this 

person or when you got the call, please don’t do anything to 

erase that, because I think we’re going to -- we’ll give you 

a subpoena on that because we’d like to pinpoint as clearly 

as we can when you got the call. 

THE ~~~FGZG: Okay. And you can’t ask them that? 

MR. WISENBERG: Pardon? 

THE WJTNESS: You can’t ask them that? 

Page 54 

MR. W.SEP~“BERG: Yes, actually, I can, but we‘d also 

Iike to know if we can get it from you. 

THE WrTNESS: Okay. 

BY MR. CRANE: 

Q To FolIow trp otHhis,*do you know why this person 

from the White House CounseI would call and tell you this, 

just out of the blue, someone you bad never talked to? 

A I have absolutely_ no clue. It was completely 

unsolicitedand,~essaid,whenIgot~messageto~ 

back,IleftamessagethatsaidtellmeifImadeamistake 

on my exit forms. 

BY MR. WISENBERG: 

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Q Did they say they had just found this document? 

A No, I don’t remember that at all. They just said 

areyouawareofadocumentandlsaidno. Andthentbey 

read it to%&and,by the content I nzalized that it was a 

document that I bad written but had not xc&led and to this 

day don’t recall writing. 

Q Did they ask you anything beyond that? 1 mean, did 

they offer -- you said you didn’t get it from them. Did they 

offer any advice? 

A Not at all. I have not talked to the White House 

Counsel about anything to do with this stuff and have sought 

nor received their advice. 

A JUROR: We do have some au&ions which we w&d 

7 your superiors could act? 

9 ~wrn%.%FWeU,thisdoeumcntwaspnzparaiin 

9 Ckt&c~ of 1996 and the decision that was ukimaw made was 

3 inAprilof 1996,sothiswaswrittkafkrtbatactionhad 

1 been taken. Maybe I’m mkunderstanding you. 

2 No representation was ever ma& ta mc of that, sir, 

3 thatthishadanyp~otherthan-itmust~,vebacnfor 

4 measpartofthetransitiantohaverespoadedtoadireetive 

5 From Ms. L-an to write a mano about any CM that bad 

5 occurred in the Off& of Legislative Correspondence. 

7 A FUROR: Were you and your superiors perhaps _ 

3 documenting your actions, to prove your actions, to be able 

9 to PToVe your actions so -- 

3 mEw-lTmss: Whenshewas-yQumealltransfaled 

I out of the White House? 

t A JUROR: That’s right. 

5 THE l%llWESS: Yes, I imagine that’s the case. 

I A JUROR: Not just her, but &o - 

j being transferred? 

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THE WITNESS: Sure. 1 bet that’s the case. But 1 

handled none of the oversight or the responsibility or tlx 

paperwork for anything to do with that. That was completely 

delegated. 

A JCXOR: Are you the person who is next in command 

after Mr. Keating? 

THE wlTN.ESS: No, there are several levels of 

hierarchy. 

A JUROR: Why did you assume the responsibility 

since there were several layers in between you? 

THE WITNESS: For which? 

A JUROR: For writing up Monica Lewinsky an9 , 

B Why did you take that respor&T&y -- 

THE WITNESS: Because my chief of staff -- 

A JUROR: - when it should have gone to the 

supervisor of Mr. Keating? 

THE WITNESS: Well, because, again, I don‘t 

remember tb~ meeting or the exact instructions, but it must 

be that I was told to do it by Ms. Lieberman. 

. _....^.. n,_ _-I+ s- _~__. ~..__.~ ~~~. __~ --*, A_ 

A JUKUK: 3x, wndr a0 you mean, you were tola zo 

do it? It would seem to me as though you realized that you 

bad inadequate information TV proceed on, that you would have 

said to Ms. Lieberman, we4 I don’t have exact information 

about -_ and I don’t have exact information about 

Monica &win&y, so let me go back to tbc people who have the 

Multi-Page m May 19,19

,’ Pge 

1 then I told him that I -- I did not make a decision myse;:. 

: 2 other than to make sure that it was considered bw wz-n 

3 higher authority. 

4 A JUROR: Wouldn’t you think of yourself, r!!, 

5 being a nunnet in this affti? r err6 THE NTITJESS: I think 1 was passing it along in 

7 chain of command appropriately, sir. 

8 BY MR. CRANE: 

9 Q Okay. Sir, you didn’t take it upon yourself to 

1 0 interview Monica Lewinslcy? 

1 1 A I didnot. 

4 2 Q And you didn’t check in to see is there some way w

1 3 can improve Monica Lewinsky’s performance. 

1 4 A I did not. And I have to say that I-- except a4

1 5 it would be my personal assistant, I would not beoxn

1 6 involved in any of the interviewing or with the people at t

1 7 sort of non-professional, man: clerical level. 

1 8 I was not involved in their selection, intervkin

1’ 9 or any of that kind of process, so 1 was not involved 

2 0 personnei at &at ievel, sir. 77~~ oniy peopie ihat i w

2 I be personally - 

2. 2 A JUROR: I’m talking about an immediate supe

2. 3 or person reviewing all of these people who are below ycu 

2x 4 THE WITNESS: I didn’t review them. That’s ri$

2. 5 And I never did. 

Page 

1 A JUROR: You participated in a process, you 

2 assumed a fust-line responsibility, did you not? 

3 THE WITNESS: In regard to? 

1 I A JUROR- You as& a fti-line Jevel of 

, 5 supervision in writing this kind of a memo. 

( 5 THEWITMSS: No. WhatIwouldsaytbatme.moisis 

. 7 thatwasmynxour&ngtotbtpersanwbohadpartici~~in 

I 5 it d&ztly on the operations side a brief recounting of the 

c 1 )situation. And so in my job, all junior person+ de&ions 

l( J were completely d&q+. It wasn’t just Ms. Lewinsky & 

1 1 - that I did not participate iri. 

1: 2 I would not - you know, when someonelilceadeptzy 

1: 3 assistant to the President hires their secretary, that’s 

11 1 something that is up to them. 

1. 5 A JUROR: But if you delegated it, sir, why did y

II 6 write this? 

1’ 7 THE wlTNE%: Because 1 must have been told b

11 6 h4s.L~tosumuxWiz tbc actions that wan taken in the 

l! 3 Office of Legislative Correspondence for that year an

21 3 again,Iusedashortbandwayofsummarizingsomethingtbat 

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not. 

2: 3 ha.cRANEz Allight. Letmefollowuponanotbu 

24 4 area. 

21 5 

Page 58 

1 real responsibility - 

2 THE wnx~SS: But she was the one who had the 

3 information. She bad worked with Mr. Keating on it and not 

I myself. 

i BY MR. WISENBERG: 

i Q I &ink we’re ta&ing about two different things. 

r I think the question from the gentleman, from tk grand 

Ijuror,was~about-thislastquestioowasnotaboutthe 

memo in O&-her, but at the time of the transfa, when Mr. 

Keating, who is your inferior, correct? 

A Yes. 

Q Comes to you and says this, why don’t you check it 

out to make sure it’s valid? 

AJUROR: yes. 

THE WITNESS: Well, I have to say it was his 

responsibility, personnel and administration were completely 

delegated to him. And tlxx I really felt I was doing the 

rightthiagwhicbwas,)vhnhtcamctomcwitbrhisnportand 

me having been there just new and not understanding how it 

worked, I said go take this to a person of higher authority 

who is in the operations side to do this, which he 

represented would be Ms. Lieberman. 

So I felt that I was accepting a recommendation 

from a person who worked for me who knew the facts - well, 

atleastasherep~~themtome-ofthesituationand A JUROR: Could 1 ask one morz question? 

_ 

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1 MR. CRANE: Okay. Go ahead. 

2 A JUROR: Do you have any sisters? 

3 THE WITNESS: A sister? Yes, I have a sister. 

4 A JUROR: A sister. If someone wrote about your 

5 sister that she engaged in extracurricular activities, whal 

6 would you think it meant? 

7 THE WITNESS: I would think that it would depend on 

8 the context. And, again, sir -- 

9 A JUROR: Let’s just say it’s about your sister. 

0 THE WITNESS: And extracurricuIar activities? 

I Well, if she were at high school, you know, that would be a 

2 goud thing. 

3 . A JUROR: No, no, no. 

4 THE WlTNESS: I_.& me just say again that in 

s light -- in terms of this document, this was written not 

6 about Ms. Lewinsky, it was written about both Ms. Izwinsb 

7 and _ the term ex&acunicuIar activities r&erred 

8 to,andIdon’tk.nowwhyIusedthatterm,butIcanassu.m 

9 you that the content of that was a shorthand representation 

o of what Mr. Keating had told me. 

1 And, again, it may sound strange that I was 

2 not involved in the day-to-day management of aIl the 

3 junior staff, but that was not my responsibility and I 

4 think I did discharge my proper responsibilities about 

5 taking the recommendation of Mr. Keating, who did have the 

May 19,1998 

Page 63 

Page 62 

responsibility, and making sure it did go to higher authority 

and was not done in a capricious way. 

BY MR. CRANE: 

Q All right. The grand juror’s question, though, was 

if someone says about your sister who is not in high school 

that she is engaged in extmcunicuhu activities, what does 

that mean to you, plain and simple? 

A It means - what it means to me is, again, I would 

have to know what the context was. 

Q Would it not raise in your mind that someone might 

think that that worn% your sister, might be engaged in some 

sort of sexual conduct? 

A Well, like any term, it’s possible to be 

interpreted and misinterpreted, out of the context in which 

it was intended. Obviously. Almost any word in the language 

is. 

Q All right. So if someone says that to you, you’re 

unable to form any opinion. 

A Without the context, I could not understand what 

it’s usage was without the context. But, again, the context 

here was as I’ve stated. 

Q We don’t need to go back into the context here. 

Let me just have you look at the date on JLK-I. 

A Sure. 

Q And it’s October 16, 1996. Now, if I have my date 

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correct, Monica Minsky was terminated about April of 1996. 

Is that correct, to the best of your recollection? 

A Yes, that recollection being refreshed by rca&n 

the newspaper accounts. 9 

Q AI1 right. And yet in October, some six months 

later, Evelyn Lieberman, Director of Operations, and you, the 

Director of Legislative Affairs, are still dealing with the 

circumstances of her termination six months later. ‘Is that 

correct? 

A Well, I don’t think so. I think’ that her 

termination had occurred in April. I was simply reporting on 

something that had happened prior that year, as I assume that 

I was requested to do. 

Q Right. But you said just a minute ago that the 

termination of Ms. Lewinsky and-was a junior 

personnet decision that you basically didn’t get involved in. 

A Letmebeveryclearaboutthat. Iamnot-Iwas 

not involved in the day-to-day management of the junior 

personnel. However, wba~ a recommcn datioocametomcfnnn 

the person who was in charge of it, I, after hearing the 

recommendation, indicated that that must be taken to a person 

of higher authority, so I became involved to assure that it 

got the proper scrutiny at a high level. 

Q Right. This is at the time they were terminated. 

A Yes. 

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Q Why then, if it’s a junior personnel decision, why, 

sir, six months later are you still involved writing memos 

justifying why they were fired, if it was such a junior 

personnel decision? 

A Again, Ms. Lieberman was - well - 

Q She put you up to it, is that a fair 

ChalXt&?HiOn? 

A Again, this Vhow words work Put you up to it - 

I don’t know the context. 

Q Sheaskedyoutodoit. _ 

A Sheaskedmetodoit. Sheaskedmetodoit. 

BY MR. WISBNBERG: 

Q You mentioned that this - earlier, we talked about 

triggering--thattfaememowhenitwasreadtoyoutriggered 

a memory of tbc meet& with Evelyn Licbcnnan. Have you told 

us everything that happened in that meeting with Evelyn 

Lieberman? 

A We& I tried to imply that because the meeting - 

I’ll repeat it - was principally about - and I don’t 

remember actually discus@ anything to da with legislative 

correspondence and perhaps that’s why, I’m just gu&ng, shtold me to write the memo, but it was about - as I t 

understoodit,aIlhea&ofofftceswembeing&ledinand~ 

said what did you do this year, how di’i you do it, what are I 

your prospects for next year, operations in transition. 

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n re: Grand Jury Proceedings Mull 

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1 And so I’m sure there was a discussion about that 

-i 2 1 m guessing now, I don’t _hr the conversation, but I’n 

3 guessing we would have talked about the legislative 

4 highlights of the year, the challenges ahead. I don’t 

5 Tecau, but I’m sure it was a broader conversation because it 

6 was part of a broad transition effort. 

7 Q And you’ve told us everything that you can remember 

8 about that in any way, shape or form that would relate t 

9 Monica -I.wins-ky. 

0 A Absolutely. 

1 Q Why would the White House essentially 

2 terminate/transfer somebody who was sick, because she’s a 

3 diabetic and because hex mother is ill? And that is the 

-:_._,:__ ,,n__. ..._...A .I._ ,,*:._ U_..^_ A,. &.,+q 4 ,_~ILuall”lL VV*uy woulo II& Vvull& nlJu3G U” LYLIL‘ 

15 A Well, that is the first time I’ve heard the 

16 assertion of those facts, if they are. Again, as I tried to 

.7 state from the beginning, every action I took and every 

8 rec~IIection I have was based on a reprtXentation that was 

9 madetome-- 

!O Q You’ve made that clear. 

i- . -2 AL-r ___^^ -...A ^“& -C.L -,-“_..m*:~.. .I A mu Uial was Ll”L yalr “I UE ‘qJ’C3cUL4L’“U. -I-hat 

!2 is the first time I’ve heard those assertions. 

!3 BY MR. CRANE: 

!4 Q Does your office lay people off because they’re 

!5 diabetic as a matter of policy? 

Page 66 

1 A I can’t imagine -- 

2 BY MR. WISENBERG: 

3 Q Your old office, Office of Legislative Affairs. 

4 A IuI&XStaIXi. ICan’t--0. I~,thiSiStk 

5 first I’ve heard of this assertion and the first I’ve heard 

6 that hypothesis, but I can’t imagine that that would be a 

7 thing anyone wouid want to do. 

8 BY MR. CRANE: 

9 Q Would you do &it? Would you yourself fire someone 

0 because they were diabetic and missing work days, missing a 

I lot of work? 

2 A No. 

3 Q Okay. Would you fire someone because they werr 

4 taking time off to care for their mother? 

5 A Again, this is the very first time I’ve heard an 

6 assertion that this was - 

7 MR. CRANE: Yes, we’ve discussed that. 

8 MR. WISENBERG: We understand that. 

9 -___ - 

BY h4.K. CmE: 

10 Q I’m asking you what you would do or what you would 

il have done as Director of Legislative Affairs. Would you fire 

.2 a person who is taking a lot of time off to care for an ill 

13 mother? 

14 A I would have -- not outright, because I would have 

15 obviously wanted to see what the circumstance, what the 

Pagem May 19,1998 

Page 67 

1 situation was and see what the situation was. But this is 

-I ,---I-*, A_._. ^ .- -^ 

L W,lqJ’“lc IICW> 1” 1‘1C. 

3 BY MR. WISENBERG: 

4 Q If you had known that Monica Lewinsky was 

5 transferred to essentially a promotion, was promoted to the 

6 Pentagon and--- if you had known that t.h 

7 reason she was sick was because she was diabetic or caring 

8 for her mother and that she not only did not get a promotion 

9 but got essentiaiiy approximateiy a iDday job assignment ai 

0 GSA that was extended one time and then she was out, would 

1 that have caused you some concern, if you had known that 

2 those were some of the more full facts behind the 

5 Was at the GSA where she got tIim.Sferred. Like I Say,other 

6 than &two-minute listening to Tii represent this to me and 

7 passing it on to higher authority, that is the extent of ml 

8 knowledge of this. So this is all hypothetical. 

9 Q Right. It is a hypothetical. 

0 A Right 

i t-I D..r ..,a#- nll....d +.. e.-L ti.o+ “..A .,A,. ..,- thn lwed y UUL WG ‘G au”WW w CDn UI6lC 411u J”U vrb.Ati Uh 1- 

2 of the office. 

3 A Right. 

4 Q You were an important person at the White House and 

5 you were at a very high tier at the White House and I’m 

Page 61 

I asking you as a supervisor, if you had known -- assume these 

2 facts are true and if you had knowo that, that Monica who 

3 basically was terminated because she couldn’t do the job and 

4 because she was a ctutch, hanging around the Oval O&e too 

5 much or tk West Wing too much, gets a promotion. and _ 

6owbo iswttoomuchbccausesk’odiab&andhcrmom 

7 is sick goes to basic&y a now*here job at the GSA. w0ti1 

8 this have concerne@you, would this have caused you to do a 

9 little investigating? 

@ A I’m here to deal with the facts as they were 

1 rep~tedtomeandasIknowthemtobe,whichisanyof 

2 these assertions you’ve just made about _ 

3 never heard them before. I acted on the representation 

4 exactly as dc~cribed by Mr. Kcating and I don’t know why I’m 

5 being asked to delve into a hypothetical, one of which the 

6 characterization of Ms. Lwinsky was also something that wa 

7 not in my consciousness until January of this pear. 

8 Q The clutch part? 

9 A y& 

0 Q The hanging around the Oval Off& too much part? 

1 A Yes. Exactly. 

2 Q BecauSe I want to know, we want to know what you 

3 would have done if you had known t&se facts. l%ese arc 

4 factors that you say you didn’t know at the time, that even 

5 now you only know because I’m presenting them to you 

_- 

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A Well, 1’11 just give you -- as I’ve tried to do in 

all my Iife, I’ve tied to treat people honorably and 

decently and do what’s right by them. And so I would have 

taken any circumstance and tried to, if I felt that was 

something unfair being done or I had reason to believe 

that there was an unfairness being dealt to someone, of 

course I would have looked at it. That was not at all tlx 

representation that was made to me in this case. 

Q And Mr. Keating in no way, shape or form indicated 

to you that Monica was a clutch or that she was hanging 

around the Oval Office too much. 

A That’s correct, although I will say it for many 

tunes that it was represented that she was away from ha duty 

station and wandering around the White House, but tbeax was 

not a representation about hanging around the Oval Office. 

And, as I told the FBI agents, I never observed her near the 

Oval Office in the times that I was near there and it was 

never represented to me that she was in the entire period I 

was there. 

And my response was our office will produce, as we 

do on a canthal basis, a recommendation for anybody wbo bas I 

worked at the White House. That was the one and o ’ 

conversation that I had with him and be never came back to me 

“f 

s 

on that_ 

Q Okay. But did you say something further, that t.br 

letter of recommendation would have to be generic? Do you 

remember teiling the FBI that, that you related that to 

Mr. Podesta? 

Q Right_ And that’s why I want to be so clear on 

this, &cause you told us earlier when you were told al&s 

wandering about the white House -- 

A It would be the West Wing. 

Q - you interpreted that to include the West Wing. 

A That’s correct.. 

A That it would have to be generic? 

Q Right_ Kind of Iike a flat boilerplate, confting 

her employment and the dates that she worked there? 

A That I would have told Mr. Podesta this? 

Q Yes. 

A In a IO-second conversation, I don’t imagine that 

I would have gone through that detail, but it is the case 

that if we - the process when they get a request for a 

letter of recommendation, the direct supervisors of that 

person draft it and deal with it, whether it’s good, bad OI 

indifferent. 

MR.cRANE: Okay. Letmereadtoyouapcxtionof 

the FBI report after the interviewed you back in February of 

this year. 

MR_ WISENBERG: And this is their report. AS 

you said, it wasn’t recorded by a tape recorder, this is 

Page 70 

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1 theii report. You’re under no requirement to agree with it. 

2 THE WITNESS: Right. 

3 MR CRANE: It says, “Hi&y also recalled a 

4 conversation with John Pod&a which oceuntxl some time 

5 between one and three months ago.“’ 

, 6’ BYMRCUNE? 

7 Q f)oyciuagreewitbthat?~ 

8 A g that plac& it - ye% That was, as you’vt 

9 reminded~Feh~~a~y~h~~I~a~~iththeF~~agents,isti 

10 right? 

I1 hm.cRANl? Right. 

12 MR. WISENBERG: February 1 Ith. 

13 MR. CRANE: One to three months prior to that 

14 THE wnms.s:. That would have been accurate. FaU 

IS of ‘97. Yes. 

16 MR. CRANE: Right. You would have had a 

1 17 conversationwithJohnPodestainthefallof’97whenyou. 

1 18 werestillattheWh&House. 

1 19 TBEWITNBSs: RiglIt. 

; !O MRCRANE: ‘Pode!stastoppulHilleyinthehallway 

: !I outside the Chief of Staffs office.” 

; ?2 mEwI-INEss: correct i 

1 

L i 

I Q But he did not tell you that she was a clutch or 

2 banging around the Oval Office. 

3 A I’m not sure what clutch means. 

i Q Somebody - a ciutch some’body who tries to be 

5 around the Resident a.II the time. 

6 A zhat was not part of the ~!pmtati011 he made to 

7 me. 

8 Q OrthatshewashangingaroundtheOvalOfficetoo 

9 much 

0 A He did not represent that to me. 

1 Q Okay. 

2 A I’ve told you completely the representation that he 

3 made to me. 

4 BY MR. CRANE: 

5 Q All right. Now, at one point, Mr. Podesta came 

6 toyouandwantedtogetanxomnren dation letter for Monica 

? Lewinsky after she had left Legislative Affairs? 

B A That’seorrecL AsItoldthePix,asI 

9 volunteered to them, there was - I don’t know when it 

3 is, but I recall this was in 1997, I think the fall of 1997, 

1 to the best of my rccollecticm. Mr. Podesta, I remember that 

z it was outside the Chief of Staffs office, near the 

3 elevator, this was approximately a 10 to I5-second 

s conversation where he asked me could our office produce a 

5 recommendation for Monica Lewinsky. 

!3 MR CRANE: Okay. *And asked Hilley if Lewinsky 

!4 had worked for Hilley.” I 

5 THE WITNESS: &-rect I 

Multi-Pagem May U&1998 

Page 69 - Page 72 

Diversified Revoting Services. Inc. (202) 296-2929 
1449 

In re: Grand Jurv Procecdinns Mull 

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BY MIX CRANE: 

Page 7: 

Q Is that correct? And you related all that to the 

FBI? As best you recall? 

A Yes. As best I recall. Yes. 

Q Okay. It continues on, the FBI report, “when 

Hilley responded in the affirmative, Podesta asked Hilley if 

Hilley would be willing to write a letter of recommendation 

for Lewinsky.” 

A My office. I wouldn’t have written it personally 

because I did not know Monica Lewinsky. 

Q All right But your office would be willing to 

write a letter of recommendation. 

A Sure. We’dwtiteonefor anyone,wkthergod,bad 

or indifferent ‘Ibat’s right. ‘I&ii supervisor would have. 

Q And you related that to Podesta 

A YeS. 1 imagineSO. 

Q ()kq! 1t n- nn "W;llP,r ?um=erl* anA WP rr4n csu 

. a. pw” VU, .A.AW, Wm.+ YIlU "V ".a.. u.., 

HilIey/your office agreed, “to write a recommendation letter 

for Lewinsky -‘I 

A Oh, no. That’s -- no. I did not - he asked if we 

would and I said wc could for anybody who worked for us, but 

he never came back to me and actua.Uy requested it. 

MR. CRANE: Okay. 

MR. WISENBERC: Okay. bzt him finish the sentence 

because it wilI put it in context. 

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MR. CRANE: I think we’re just getting ahead of 

ourselves. Let me read the whole sentence and then you 

explain. 

1 

I 

1 employers, 

i A Right. 

“H&y agreed to write a recommendation letter for 

Lewinsky, since it was office practice to write letters for 

all former employees of Legislative Affairs. 

“H&y explained to Podesta that due to the less 

than favorable circumstances of Lewinsky’s leaving 

Legislative Affairs, the letter would have to be ‘generic,’ 

confirming LewinsI$s employment and dates. Podesta 

indicated that Podesta would get back to Hilley on the 

matter, but to date has not done so.” 

THE WlTNEZSS: Idon’t recall using the generic 

thing. That’s not a thing -- a phrase I use. But 

substantially it is correct, that he asked me could our 

_IlE__ __1*_ _ 1-_- -r ^_11_.^_ T A,-,. --_I, :I r Orrrr*; -CC a KKUX, 1SiilU YCS. 1 UUIl L JU3JJ JJ 1 - 

you know, alerted him or recalled for him - and I don’t know 

what be knew or w!@ever, about the situation, that she in 

fact had been transferred out in 1996. And so that’s 

basically it. 

BY MR. CRANE: 

Q I think you described a minute ago that your offia 

has a policy that you will write a letter to prospective 

Page 74 

Pagem May 19,1998 

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Q A recommendation letter, but it may be good, bzd, 

indifferent. 

A Right. Depending on what the supervisor of that 

person, the opinion is, who actually supervised them. ; 

Q All right. So in your terminology, an indifferent i 

letter of recommendation or a generic letter of 

recommendation that just confirms the person’s dates that 

they worked there, that’s what your office would have done 

for Monica Lewinsky? Is that correct? 

A Well, I don’t know -- no. I mean, 1 don’t recall 

this whole generic and dates of anything conversation. 

Q Okay. Cut out the generic and just -- 

A And the dates -- but what I can tell you is that if 

h4r. Podesta would have actudy made that request of our 

office, 1 would have delegated that to her supervisors or 

thosewho had familiarity with her to draft such a letter 

Y RV a ..Yb L4R WlCfihTRlzRr.. ..A"Y..Ul_r..U.. 

Q Well, you said you volunteered this information t 

the Bureau, correct? 

A Yes. 

Q And it says “Hilley explained to Podesta that due 

to the less than favorable circumstances of Lewinsky’s 

leaving Legislative Affairs,” then it goes on. Do you recall 

telling that to the FBI, that you explained to Podesta that 

she left under less than favorable circumstances? 

Page 7t 

1 A At this time, I don‘t recall that piece of the 

2 conversation with John Podesta 

3 MR. WSENBERG: We have to take a quick bnzak. 

4 MRCRANE: Okay. 

5 MR. WEENBERG: I’m going to ask you if you could 

6 step outside for just a minute or two. 

7 May the witness be excused? 

B THE FOREP&!SON: Yes, he may. 

9 (Thewitnesswasexcused_) 

0 (Whereupon, at 358 p-m-, the taking of testimony 

1 in the presence of a full quorum of the Grand Jury was 

2 concluded.) 

3 ***** 

Page 73 - Pagf56 

~ivcrsifki Rcporthg h-vices, Inc. (202) 29629?9 
1450 
In Rc: Grand Jurv Proceedings 

Tuelday, n.y 26, 1996 

scprmber 19, 1997, c-nch9 .L 10:47 ..n. betore: 

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9 Q 

0 A 

1 Q 

2 A 

3 Q 

Multi-Page’>’ ‘i’ucsday, May 26,1998 

I 

Page 

1 A Thrit’s fine. 

2 Q The litany of rights, the Fifth Amendment right, 

3 the secrecy proceedings, unless you ask me to. 

4 A That’s fiX2. Thank YOU. 

5 Q But I think they were fairly explanatory and we cm 

6 get right to it. 

7 A Mm-hmm. 

8 Q Okay. Let’s go tight into ihe factud questions, 

9 then, Do you know how long it was, sir, after the decision 

I 0 was made to terminate Monica Lewinsky’s employment in 

J 1 Legislative Affairs that she actually left? 

1 2 A Say that again for me? The decision? 

J 3 Q How long From the time the decision was made by you 

J 4 together with Mr. Keating. 

J 5 A Well, that’s what I want to be careful about 

J 6 because,again, my only involvement in this was when 

1 7 Mr. Keating came to me in my office - 

1s 8 Q AI1 right. 

11 9A -- and I did what I considered appropriate, which 

2( 1 was, not knowing the facts of the case, but b&ed on his 

2. I representation, I told him -- at his suggestign, agreed to 

2: I take it to a person of higher authority and then I had no 

2: 1 direct involvemen$ in it. So I don’t know when tiat decision 

21 4 to actually terminate was made. 

21 5 Q Okay. But from the time you had the discussion 

Page 1 

I with Mr. Keating until Monica actually left, do you recal1 

. 

, that length of time? 

A WelI, 1 think I do, but I think also it’s because 

1 of having read in the paper subsequently that I think ti 

1 left in an April timeframe. I think, that’s my recollection 

( From the paper. And I think Mr. bating - like I say, I was 

c 

; 

new- must have come to me, I think, I’m guessing, about a 

month - v a mom% and IWO ,mont&s after I arriuzd and I 

S arrived in Fibruary. 

JC Q All right. And you arrived in February, a month or 

II two months later, Mr. Kfziting comes to.you, so we are going 

1; to be into March or April? 

l? A I imagine. I can’t help you exactly, but that 

14 makes sense. Yes. 

IS Q All right. Is this a fair characterization, sir, 

16 that it was a fairly short period of time before Ms. Lewinsky 

17 actually left Legislative Affairs? It didn’t take long to. 

18 get her out, to put it bluntly. 

19 A Again, the only way I know that it actually 

20 occuntdwasbtcaux;tbtpasonwhowasmondtobttbencw 

21 person in legislative correspondence was a young man named 

2: L ChrisWalkertidthatoccurred,Ithink,somztinieinthe 

21 I spring as well. But my best guess would be something in a 

_- 

24 

2! 

Page 2 

1 PROCEEDINGS 

2 w+eupon, 

3 JOHN LEE HILLEY 

4 was called as a witness and, af& having been duly sworn by 

5 the Foreperson of the GFd Jury, was examined and testified 

6 as follows: 

EXAMINATION 

BYMR.CRANEZ 

Good morning, Mr. Hilley. 

Good morning. 

My name is J;?, Crane. 

Hi, h4r. Crane. 

And, of course, we XXI lad week while you were in 

1 

1 

1 

1 4 here for some time. And I apologize for the delay. 

1 5 A That’s okay. I understand. 

Jl 6 Q We had some difficulty getting some jurors here 

1’ 

T 

I because of some family crises that were going on. 

11 8 Let’s see. State your full name again just for the 

I’ 9 record. 

21 0 A John Lee Hilley, H-i-l-l-e-y. 

2 J Q All right. And you previously appeared before this 

2 r5? Gibraltar oq vay 19, 1998. Is that correct? 

23 A A week ago, I believe. Yes. 

24 Q fight.. Okay. At this point, I will not go through 

25 all bf your rights and privileges. 

I month or two range4 again, bchvam the time he came to se me 

5 and, I believe, the time she left. I’m guessing. 

II 

Page 1 -P ‘age 4 
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In Re: Grand JW Procccdirxs Multi-PagcTM Tuesday, May 26,199 

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Q Okay. Let me show you what we’ve earlier labelled 

as Grand J-q Exhibit ILK-I, your initials. 

A %I.X. 

Q This is this memo that uses the phrase 

“extracurricular activities” that we talked about at some 

length. 

A That’s correct, 

Q Now, in recent months, other lhan your appearant: 

here at the grand jury last week, May 1901, when was the 

previous occasion that you saw this memo? 

A Well, could I just go back a second? 

Q Sure. 

A Well, I must have written the memo, so I must have 

seen it then. 

Q Right. 

A Which would have been either October 15th, 16th 

somewhere around there, of 1996. And then like I 

testified, the fact that I wrote this memo had faIlen froxr 

my memory. 

Q tight. 

A And then I was given a reminder of that fact here 

in the: last - fairly recently -- month or two. And, like 1 

testified, with an unsolicited phone call from the White 

House Counsel’s Office -- I don’t need to go through all that 

detail? 

Page 6 

I Q No. My question to you was befote you came to the 

! grand jury, when had you last seen this memo? 

I A We& I know you had a conversation with my lawyer 

I about this, 

i Q tighti A And so I want to be strictly in line with that, but 

1 IdidsaythatIdidseeitaadlthinkI Q What timeframe? 

I A Oh, it was just right before I came in to testify. 

I Withinawe.ekofthetirncorafewcIaysoftbetirnewhenI 

I came in to testify last Tuesday. Just a few days. 

2 Q And how did you get it? 

3 A Through mUnSei. 

4 Q Okay. 

5 A My counsel. 

5 Q Right. 

I A Right. 

1 Q Now, we also talked when you were here last time 

P about your conversations with a Mr. Podesta. 

1 A That’s Correct. 

, Q And I’m referring to in particular after Monica 

! Lewinsky had left Legislative Affairs. Now, tell us again, 

I who is Mr. Podesta? 

I A Mr. Podesta is the Deputy Chief of Staff at the 

i White House. 

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Q All right. And what was the nature of his _ 

conversazion there with you in the hallway? 

A Al; @ht. This was, again, some months ago ano L,, 

the best of my recollection, I would guess it was in the late 

fall of 1997, but I am net sure of the date, when it was. 

But I recall that I was outside the Chief of Staff’s offic: 

on the fm floor of the West Wing of the White House and 

Mr. Podwta came up to me. 

1 recall it was sort of right in front of the 

elevators and people were passing Co and fro. And in a very 

brief conversation asked me if our oflice would produce or 

could prodxe a recommendation on hehalf of Ms. Lx&sky. 

Q Okay. And Podesta is the Deputy Chief of Staff? 

Is that correct? Or was? 

A That’s correct Well, he currently is. 

Q Currently is? 

A He was at that time and currently is. 

Q And so his immediate boss is the Chief of Staff. 

A That’s correct. 

Q And at that time, it was still Leon Panetta or it 

I was Erslcine Bowles? 

2 A No, this was Erskine Bowles. Mt. Podesta was 

3 brought in by Mr. Bowles as one of his deputies. 

1 Q AI1 right. So is this fair to say that Ersk.ine 

5 Bowles, apart from the PresidenS is the number one rn‘ . 

Page b 

I the White House? 

! A In terms of staff responsibility - well, in terms 

I of staff responsibilities, yes. He’s the most senior staff 

I person. 

i Q AII right. And t&n number hvo would be the Rputy 

i Chief of StaffbPodesta in this case? 

r A In terms of operational hierarchy, there’s actually 

I two of them. Two Deputy Chiefs of Staffs. 

1 Q AlI fight. So is this a fair characterization, 

o sir, that this request for a letter of recommendation for 

II Ms.Lewinskywas~gfromfairlyhighupintheWhite 

12 l-louse hierarchy? 

13 A Yes. It was coming from the Deputy Chief of Staff. 

14 Q And did it strike you as umrsuaf that a woman who 

!5 had b&n tcmhatal some months ago was now having tlx Deputy 

6 Chief of Staff or was the recipient of a request for .a 

7 recommendation on the part of the Deputy Chief of Staff? 

8 Do you see what I’m getting at? 

9 A Yes, I do. At the time, I didn’t t&t& much about 

!O it. I get requests for hundreds of things a day. But given 

!I in light of what’s become public since then, and perhap : 

2 why I recalled this event, that it did stick in memory, that 

3 he had approached me about this. 

4 Q All right. So is this a fair characterization, 

5 that at one moment your line deputy, Mr. Kcating, together 

_~ 
1453 

In Rc: Grand Jury Pracecdings Multi-Page ix! Tuesday, May 26,199s 

Page 5 1 Page 1 

1 with Evelyn Lieberman are working to terminate Monica I a year and a half la::, Mr. Podesta is wanting to know 

2 Lewinsky? 2 whether she can get a letter of recommendation. 

3 A That ~3s the result of what they came out with. 3 A That’s correct. 

4 Yes. 4 Q That’s our t&frame? 

5 Q Right. And then -- 5 A That’s correc: Yes, it is. 

6 A As well as -- I would like to establish the 6 Q At any point, tld you say to Mr. Podesta, “Wait 

7 context, please, that it was brought to me as nothing about 7 minute. This is the in’rm that Evelyn Lieberman and Tim 

8 Monica Lewinsky was brought to me separately with regard tc II 8 Keating canned or g_n; rid of?” 

9 h4.r. Keating. 9 A Well, again, i: was a brief conversation. I know 

0 When he originally came to me after I had just 1 0 these are all very impcrant events in people’s lives, but at 

f begun at tbc white House, be came with a rccommcndation about 1 1 that time, not knowing the events that have unfolded 

2 wanting to deal with the entire, which was two people, 1 2 subsequently, it was a very peripheral issue to me and I 

3 legislative correspondence shop, so it wasn’t about Monica 1 3 didn’t think much of it 

4 L.ewidy solely, it was about the performance of the office ! 4 But I could have said, because I did remember th 

5 itself. 1 5 names of tbc people who bad b&n tcaminatcd, so it would have 

6 Q Okay. But I’m talking about right DOW just Monica 1 6 beeu consistent as things were represented to me to hav 

7 Lewinsky. I 7 said, you know, this carld probably only be a standard or, I 

8 A Okay. 1 8 think the words that the FBI used last time, generic lette 

9 Q True,- was also terminated or I 9 that could be written on Ms. Lewinsky’s behalf. 

o transferred. 2 ‘0 I want to be clear, I could not have myself written 

1 A Right.. 2 .I the letter nor would have agreed to, since I did not know her 

2 Q But at one point in time, Mr. Keating together 2 2 or her work product personally. 

3 with Evelyn Lieberman, to basically get her fired. True’ ?2 13 Q All right. And do you have any insight as to wh) 

4 A Well, that’s your characterization of the word. 2 4 in light of your experience in the White House why at one 

5 I always took it -- he came to me, that they wanted to move 2 85 moment basically people are ganging up on Monica to get ric 

Page 10 Page 1: 

1 them out or transfer the tvrio of them, but that’s your I of her and then the next moment the Deputy Chief of Staff 

2 characterization, yes. And they were terminated from 2 wants to get her a letter of recommendation? 

3 employment at the White House. That‘s correct. Yes. 3 A Well, again, I’m just trying to be fair to people 

4 Q Okay. I think the terms that you use in the memo 4 on all sides and tell the court everything I know about these 

5 aretoget&dof? 5 incidents. 

6 A Right. Sure. That’s an accurate -yes. 6 And so the chamcterizations of ganging up, et 

7 Q Okay. So the most accurate phrasing would be, as 7 ct~again,Idoaot~wthcfaclsof~wasgoing~. 

8 you say in your memo, “we got rid of Monica and Jo&m”? 8 Evaything ‘I r@ was b&d on reprtscatatioas made to me, and 

9 A That’scorrect. 9 so to - you know, the &aracterizations would not be mine 

0 Q Okay. Whether they’re technically fred or 1 o because I just tried to represent this factually. 

I t, transferred under very unhappy circumstances - 1 1 But it is tkvz case that Mr. Podesta came to me ant 

;2 A Right. It was an involuntary SqMmtiOII for sure. 1 2 asked that question and, like I said, that was the one anI 

13 Q All right. And a few months later, Mr. Podesta, 1 3 only time he approached on me on it, about this. 

14 the number two man in the staff of the White House is 1, 4 Q All right. 

,5 wondering whether she can get - I! 5 A But he did ask me about that and, of course, that’s 

86 A I’m sorry, maybe I didn’t hear you. Did you say a 1t 5 what I volunteered to the FBI. 

i7 few months later? 1’ 7 Q Now, there was some question about whether 

18 Q Yes. II B Ms. tinsky and-had allowed correspondence to 

19 A Well, -and Ms. Lewinsky left the White I! ? back up in the Off& of Legislative Affairs correspondence 

21 D division. What do you understand about that and how much Of 

2 I a back log there might have been? 

2: 2 A Wkn Mr. Keating came to me, again, being new, 

2: 3 inherited the entire staff and at thattime 1 did not know 

21 4the quality or the work product of any of my employees that : 

2: s had inherited. 

10 House in sort of the spring of 1996. As 1 recall, it was 

I1 not until the following year, ‘97, late ‘97, if that, that 

!2 Mr.Podestacametome,soitwasayearandaha!flater. 

I 23 Q A year and a half later. 

24 A Yes. A year and a half. 

25 Q Okay. I stand corrected on that timeframe. But 

9- 12 

-.. 
1454 

In Rc: Grand Jury Procccdiqs Multi-Pap TH 

I 

Tuesday, May 26, 199 

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He did represent that there was a problem of the 

mail being backlo, Ofled, as you say, or getting out slowly 

And the only recollection I have that’s specific is there was 

some reference to the mail about OMB mail or some location o 

mail to do with OhIB was a problem. 

Q And do you know how long this backlog was? Did he 

ever tell you how long? 

A No. Again, because of the nature of my 

responsibilities, being responsible for all of Congress as 

well as every branch of the administration as regards federal 

legislation, I did not direct the Office of Legislative 

Correspondence. I had no direct knowledge of its 

functioning. 

Q All right. Now, was Mr. Keating able in his 

position to terminate or transfer a low level staffer, or 

low level staffers plural, like Ms. L.+nsky and 0 

on his own? 

A Well, as indicated by what I asked him to do and 

based on tt)e fact that I did not know the work of the two 

women, I would have not, I think, allowed &hat and so I don’t 

think it would have been in his authority. And, again, 

that’s why I requested that he go to a person of higher 

authority, who was Ms. Evelyn Lieberman, the Deputy Chief of 

Staff, at that time. 

Q Okay. But my question is could he. 

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A I don’t know. I don’t know. I mean, again, as we 

talked about last we&, this was the only unhappy personnel 

situation that came up during my tenure, so there was nc 

other ease and, in this one ease, neither he nor I, you know, 

saw fit to exercise that on our own. And I didn’t know if I 

even had the authority, to be honest. I had just walked in 

the door. 

Q Nobody ever told you whether you had hiring or 

fting authority? 

A No. That’s why I said take it upstairs. 

Q Did you ever fmd out later whether you had hiring 

or firing authority? 

A No one ever discussed that with me. No. I mean, 

our off& hires people. We interview people and such but 

it’s always -- I imagine there’s some bureaucracy that has 

to approve in the Office of Administration ultimately all 

7 decisions that ax made, so I don’t think I have sole ability 

8 to do that. It has to be cleared again, through the system. 

9 Q Okay.* But could Mr. Keating have just gone to 

D Evelyn Lieberman and cleared it through the system that way? 

1 A Of course. I imagine because Ms. Lieberman’s 

2 responsibility was for the operational side of the White 

3 House, so I take it that she would he the person situated to 

4 effect that. Yes. 

5 Q All right. So is this a fair characterization, 

1 

2 

3 

4 

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Mr. Hilley, that Mr. Keating did not need to come to you to 

get a low level staffer like Ms. Lewinsky or __ 

transferred, he could have gone directly to EMS. Lieberm,.{ 

A He could have but even as his new boss who had 

never worked with him, I think that would have barn a bit of 

an insult to me not to even inform me that he was going to 

take it up to another person, so I think he did the right 

thing in bringing it to me and I think it was the right thing 

to kick it upstairs. 

Q But these were extremely low level people, as I 

tink you may have -- 

.4 They were junior staff. Yes. 

Q All right. And it wouldn’t have been appropriate 

for him to see to the transfer of low level junior staff? 

A By himself? 

Q Together with Ms. Lieberman? 

A Oh, 1 do believe that together with 

Ms. Lieberman -- I’m sort of assuming this, but because 

of her position as the Deputy .Chief of Staff, I think the 

two of them together and Ms. Lie-an knowing how the 

11 bureaucracy worked of course would have been able to do 

22 that. 

23 Q All right. 

14 A That’s my supposition. 

25 Q Do you know whether Ms. Lieherman even neex. c 

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input to transfer or terminate Ms. Lewinsky and-r 

could she have done that on her own? 

A I really don’t know her authority. 

Q Now, in your memo here, JLH-1, you refer to, I 

believe, in the fust sentence, Ms. Liebennan pnparing her 

own memo. 

A YeS. * 

Q Did you ever see a copy of that memo that came back 

to you? 

A No. AsIunder&odit,thememowasaotbeingif you meant prepared for me, I never saw it and my 

understanding was, as I said a week ago, that I believe that 

becauscallofthedepartmentheadswerebeingealledinto 

ask how their operation was mnning, that this was a memo 

being prepared in line with the transition because the 

current Chief of Staff was leaving, Leon Panetta, and she had 

been made sort of the head of transition. 

Q AI1 right. So the basic answer is you weren’t cc’d 

on whatever memo -- 

A No, I wasn’t. No, I wasn’t. 

Q Okay. Were there any other personnel form ’ It 

you had to sign off on like a @ice of transfer or any 

standard OMB forms, notice of separation or not& of ._. 

transfer, in order to get Ms. L.ewinsky and n I 

5 transferred out? 
1455 

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In Rc: Grand Jury Proceedings Multi-Pagcm 

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Tuesday, May 26, 1998 

Page 1’ 7 Page 19 

A 1 do not recall seeing any such forms. I know 1 Again, they had been in the office for -- I’m not sure how 

that -- the only forms in my two years there that I recall 2 long bcforc I cam onto the sccnc and what had gone on b&,E 

siqing was W~J there was a person getting a raise or a new 3 that, I don’t know, but he never -- it’s not my recollecti& 

person being hired or a change of job title, that paperwork 4 that that was a part of it, that there had been wmings 01 

would be put in front of me. I do not have a recollection, 5 whatever. But, again, I didn’t deal with it directly and he 

although it’s possible, since I signed other papers. 6 would be the person to ask. 

In my two years there, again, I remember signing 7 Q All right. And, as far a.~ you know, Evclytl 

basically raises, change of job title and the hiring of 8 Lieberman never gave Ms. Lewir~ky in particular any son of a 

folks, but I don’t recall being asked to sign any paperwork 9 written warning or reprimand. 

with regard to either r Ms. Lewinsky, although I 1 0 A As far as I know. Bu< again, ! probably wasn’t : 

can’t rule it out because I can’t remember. 1 i a position to know and she would be the one who would lcno 

Q All right And Z believe I’ve already asked you 1 2 that. 

how long it was from Tim Keating’s visit until Ms. Lewinslq ’ 1 3 

and _ were actuaily terminated. 

Q Okay. Now, did Mr. Exskine Bowles ever have any 

1 4 conversations with you about Monica Lewinsky? 

A And I would guess, again, 1 have trouble with 1 5 A Never. Iust asI'vetiadachan~t0se~ecton 

specifics, but I would guess a month to two months, would be : I 6 this, theseevents intersected my life three times in my two 

my guess. :%!$i& 1 7 years at the white Houst: when Mr. Kcating came to me, when 

Q Did one individual or two individuals take their I 8 Ms. Lieberman requested this memo, and when Mr. Podesta 

place? 1 9 approached me in the hallway, are the ones that 1 recall when 

A I do not know. The only one I know, as I’ve told 2 0 this intersected my life. And I have no recoilection of 

you, was Chris Walker because it directly impacted me in tha t2 1 Mr. Bowles ever mentioning Monica Lewinsky to me. 

he was the in effect administrative assistant that I had 2 2 Q All right. Did Mr. Podesta ever ask you for 

inherited from my predecessor. I don‘t know what they did 2 3 letters of recommendation for anyone else within your office 

with the office, if it was one or two. I just know that 2 4 at the time you were at the White House? 

Mr. Walker went over there to, I believe, head it up. 2 5 A I don’t recall him ever d&g that. No. 

Page 18 Page 2( 

1 Q All right Now, was Mr. Walker already working 1 Q All right. In the week since we have met, have you 

2 within your office? 2 had any phone calls from the Off& of White House Counsel 

3 A Yes. 3 A No, I have not. 

4 Q Okay. In a different position? 4 Q Has any other person, investigator, anyone other 

5 A That's con&t. He was my personal assistant, 5 than your attorney asked you, or a close family member, aske 

6 which I had inherited from my predecessor. 6 you about your testimony? 

7 Q All right. So you were more familiar with him. 7 A No. No, sir. 

8. A Yes,Iwas. 8 UR. G.wE * there any questions from the 

9 Q And&ycubwwbtbewas toldaboutwhyhewas , 

10 taking over Ms. Lewinsky’s and- job? 

9 members of the grand jqy? 

11 0 A JUROR: Mr. Hilley, you indicated that you were 

A I don’t at all. I think -- I mean, this is all 1 1 not cc’d on any memoranda prepared by Mrs. Liebennan. Is 

very hazy, but 1 believe that Mr. Walker, to me, indicated a 1 2 that correct? 

willingness to want to go over there because I think he 1 3 THE WITNESS: I don’t believe 1 was. No. 

probably didn’r wear make me feel bad !bar be was leaving me Id 4A JLrROR: Do you have any Z&XXI to know whether 

for something else, but I do recall that he indicated to me I: 5such a memorandum actually was prepared? 

that this was something he wanted to do. But how he was II 6 THE WITNESS: 1 have to guess. I don’t know, but 

approached or it was described to him, I don’t know. 1' 7 I’m guessing that it was because, as I recaI1, I think I 

Q All right. Let’s see. Tberewereno warning II 6 was asked to do this because she was preparing something as 

letters or no orobation oeriod for either Ms. Lewinsky 01 : I! P 

. 

_ 

part of the transition. 

-prior to their fting. Is that correct? 2f 3 I mean, I don’t know why 1 would have been asked 

A Not that I’m aware of. No. 2 1 to write this unless there was something else in the works, 

Q Okay. Neither that you would have issued or 2: 2but I don’t kriow the nature of it. 

23 Mr. Tim Keating? 2: 3A JUROR: So whatever was poduced by 

24 A Certainly that I’m aware of. Rat’s COT'XCt. 2* 4Mrs. Lieberman probably still exists somewhere, wouldn’t 

25 You’d have to ask him if he had done something before. 2. 5it? 

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1456 

In Rc: Grand Jurv Procccdinm MUI 

Page 2 

1 THE WIR\I’ESS: It was produced, it probably woulc 

2 If this still exists, I would think that would exist, too. 

3 A XIROR: Thank you. 

4 MR. CR4KE: All right. If there are no further 

s questions from any of the members of the grand jury, we will 

6 excuse hdr. Hilley. 

7 THE WESS: Do you want this back? 

8 MR. CRANE: Yes. Thank you, sir. 

9 THE MESS: Okay. 

10 MR. CRANE: And, again, sorry about the delay. 

I1 THE WITNESS: No, I understand. 

12 MR CRANE: Thank you for coming on two occasions. 

13 IT-E wrrNE.SS: That’s fine. ihank you. 

14 THE FOREPERSON: Thank you. 

I5 MR. CRANE: Thank YOU, sir. 

16 (The witness was excused.)_,_ 

1-l (Whereupon, at 11: 15 a.m., the taking of testimony 

IS in the presence of a full quorum of the Grand Jury was 

19 concluded.) 

10 ***** 

-Pagcm Tuesday, May 26,199 

_______J - - 
1457 

l?$q 

October 16, 1996 

Dear Evelyn, 

Thanks for the meeting yesterday. I wanted to follow up on a 

few points as you put your memo together. 

0 I've enclosed our staff division of responsibilities that we 

use throughout the year. I don't distribute it because I want 

White House and agency staff to funnel their issues and requests 

through our West Wing operation. That way I can keep track, 

exercise quality control, and make the judgements about the use 

of our staff resources. 

0 I've also enclosed a brief memo on our correspondence 

operation. It was in bad shape when I came in. We got rid of 

Monica and- not only because of "extracurricular 

activities" but because they couldn't do the job. We also had 

problems with NSC and White House correspondence that have been 

corrected. I believe the operation is in quite good shape now. 

Thank you for being so good to me this year. I greatly 

appreciate your help and counsel. I will take the steps you 

suggested and then follow up with both you and Leon. 

1089~DC-ooooo970 

GOVERNMENT 

EXHJBK 

ii&A-- 

G\ w\w 

0 004647 

I 

c 
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tar ttm District or co1mmbia 

3rd ‘ CansCltUtlOn. tl.W. 

llaahinqton, O.C. 20001 

. 

nre: GrandhyProaedmg s Multi-Pagem August 13,1998 

3 

me t~atlrony of umr nous- “.S taken In the 

pr.m.cr of . full quaxm of Grand Jury 97-2, impu1.1.d 01 

sapteam 19, 1997, -ncinq .t 1:47 p-r., betor.: 

9WJ.M 

mnY ANm WIRTH 

A,sociatm In&pnd.nt couna~l 

ott1ca of Inde~ndonf couna*1 

1001 PelLm8ylvulia Avmue, Ii.*. 

suite 490 mrth 

YuhlnqtDn, O.C. 20004 

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A okay. 

Q ncpcrsonimmaliatcJyiafmotofyouandtoyour 

leftistbcfxurtxcpcrM. Shcistakiagdowamryrhing 

that’ssaidkxctodayandtbacwillbcaraxm%a 

transcript, made of tbc questions and answus, *Iask 

tbanormanba-softbtgrandjuryaskthanofyou Doyou 

undastaod that? 

A Yes, sir. 

Q Iwanttodlyoutbatfcdaalruksofcriminal 

pmccdlnzprob.iiittkdiscbsurcofmatkrsoccmTiogbcfcae 

thtgrandjmywhichwouldinclu&yourteetimonycrdba 

thingsthathappa3aiduringyourappcammxluetuiay. 

Thatnrlc,boVMr,onlyco5trolsmanbusofthe 

grandjury,mysclfaanothrrattomcyfortbcOff’ictof 

IndcpaxkntCouasdandtbecourtreparoer. 1tdoeanottcll 

youwhatyoucansayofcan’tsayafbxyoumakeyour 

appcaranccbaztoday. Iaothuwords,youcaukavetbis 

rmmandhaveaprssconf~ifyousocbooseaboutwhst 

happcnea~today. 

Tha-caresanccxc45ption&bowrcver,andIwaIltto 

adviseyouoftbau GncoftbcmisiftbccouItoKkzsthat 

thistcatimonybcdisckxxa&forcxamplc,inatrialorin 

anotkrprocadin&tbartbcse.cKeysurroundingwhatbappcns 

todaywouldgoawaybyvirtucofthatcourtordcr. Doyou 

lmdcrstand that? 

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Page 2 

PROCEEDINGS 

-pea, 

LARRY HOUSEHOLDER 

wascalkdasawitncasand,aftcrhavingbanfirstduly 

swoanbytbcFoqason ofthcGlandJuIy,wasexamixdand 

tartif-ial as folk%v!x 

EXAMINATION 

BY MR. PAGE: 

Q Sir,wouldyoutellusyourfullaamc,pkase? 

A Lany Houscboldu. 

Q Isitofficeroragent? 

A Yes, sir. officer. 

Q Off&r. what do you work? 

A Rightnow,IworkattbcForcignhfissioosBranchup 

on IntnQational Drive. 

AJUROR: Wouldyouspcllyourlastname? 

THE WlTNESS: H-o-u-s-h-o-ldcr. 

BY MR. PAGE: 

Q Allright. Bcfcntwegctstiwithyour 

questions, I want to explain some things to you. Tbc fmt 

isthatthisisafaicralgrandjuxyandthisfcdaalgrand 

jury is investigating c&ain mattas involving Monica 

Lcwinskyandotbasandw~~wasanGfforttosuboro 

pajury, solicit pajuq oa bcibalfof othas, obstxuc~ 

justiccintlxcivilcaseJoncsv.Clinton. Allright? 

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A Yes,sir. 

Page 1 

Q -right. Soinotherwords,tbebasicr&of 

secrecyandthensomeexceptionstoit. Doyouundastand 

that? 

A Yes,sir. 

Q Youareappearingherepunuanttoasubpoeaa, 

unTect? 

A Yes,&. 

Q Anddoyouunderstaudthattheoaththatyouwere 

. . admmaxdqtiyoutospeakthewholetruthand 

nothing but the truth during your testimmy today? 

A Yes, sir. 

Q Do you m&stand that you can’t say you forget 

when you really don’t forget? 

A Yes. 

Q Andthatyoudon’trememberwbmyoumallydo 

remember? 

A Right. 

Q It also prohibits you from giving misleading 

testimony as well as false testimony. Do you untid 

that? 

A &s,.sir. 

Q Doyouundmtandthatyoubavecertainrightshere 

todayand~ofthemisy~FifthAmendmentrighttonot 

incriminate yoursa? Do you understand that? 
1460 

In rc: Grand Jury Prowdings MUlti-PagCm August 13,1998 

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Q Howtbatworksistbk. Ifyouranswcrtoanyof 

tixqu&ionstbatyouareaskaitoday,ifatfuthfulanswa 

wouldtaKlto kliminateyo&youbavethcrigbttoranaitl 

sikntorsay”zlEfilsetD m that.” Do you undastand 

that? 

A Yes, sir. 

Q Doyouundastandthatinmakkganappcarancc 

beflxettlegraDdjlxymostwitnesssfaUintcleithcrhvo 

catcgorks? Oncisatargqmcaningtbattbcgrandjuryba.s 

substantial evikcc linking that witness, that tar@, to 

tkcolmnissimofacrimandtbatintkgrandjury’svicw 

that is w that they in-d to indict. The SQcond 

ca~ofwibxssesisqui~broadandtbatisgrandjllry 

~arcoflacalkdsubjaztsoftbcgrandjury 

investigation and all &at m is that conduct is witbin 

tbt scope of tk grand jury’s investigation. 

I~ttoyouthatyou’nnotafargctand 

tkt you’re not a subject in tbc saxse tbat your conduct is 

witbinthcscupcoftbcgrandjury’slitaalinvestigati~ 

but you’re m Eke a fact witness. For example, a bank 

tdkrwbosebnnkwasrobbalandwbobappaxdtoscetbcban~ 

getting mbbal. Do you undcaxtand that? 

A Yes,& 

Q All@& Doyouunckstandfiatbatbatyoubavc 

Page6 

1 a right and the grand jury would permit you a reasonable 

2 opporhmity to step outside and to consult with Matt Dates, 

3 the lawyer that’s present for the Secret service, and any 

4 other lawyer that you chose to have present today? 

5 A Yes,sir. 

6 Q IsMat.tDatesoutsi&? 

7 A &s,sir. 

8 Q And available? 

9 A Yes,& 

0 Q All right. Do you have any questions of me before 

1 wegetstalkd? 

2 A No, sir. 

3 Q How long have you been with the Secret Sexvice? 

4 A Over26years. 

5 Q Andyousaidattheoutsetyourcumzntassignmen 

6 waswhat? 

7 A I’m at Foreign Missions Branch. 

8 Q You’ll have to - 

9 A Foreign Missions Branch. 

0 Q Foreign Missions Branch? 

1 A It’s on International Drive. 

2 Q All right. Before that, what was your assignment? 

3 A IwasattheWhiteHouse. 

4 Q And what were the approximate dates of the period 

5 oftimethatyouwereass@nedtotheWhiteHouse? 

Page 7 

1 A Erom-IbelieveitwasaroundJuneof’92througb 

2 Novemba of 1997. 

3 Q So since approximately November of ‘97, you’ve k 

4 assiped to the Foreign Missions Branch? 

5 A 

6 Q 

7 A 

8 Q 

9 A 

10 Q 

!I A 

12 Q 

Yes, sir. 

Is that a promotion for you? 

No, sir. 

From June of ‘92 through November of ‘97 -- 

I’msorry,itwasJuoeof’82. . 

I’m sorry? 

Jlrne 1982. 

Juneof’82. Excuseme. From3untof’82througb 

13 Novenkof’97whenyouwenzattheWhiteHouse,didyou 

.4 holdanumberof =&nments during that pexiod? 

.5 A Yes,& 

6 Q Wbatwasthelastonejustbef~yourtmnsfkrin 

,7 Novemk of ‘97? 

8 A Iwasjustanunassignedofficer. 

9 Q And for how long before November of ‘97 did you 

!o hold unwigwd offku? 

!I A Far approximately a year and a balf. 

!2 Q SowouldthatbeapproximatelyMayof’96or 

!3 &x&ours? 

!4 A May, June of ‘97. 

Y 0 Alxlbeforethat? Yournexttotklastasskment? 

Pagef 

1 A Itwaswithtbespecialopuationsxztionasa 

2 touroffkr. 

3 Q Andthatwouldhavebeenfromwhattime, 

4 approxkitely? 

5 A Itwasathreeyearperiocl. 

6 Q So May or June of ‘93, approximatelfl 

7 A Yes,sir. 

8 Q TlnnughMayorJuneof9 A ‘96. 

0 Q- ‘96. Do you know a person by tbe mme of Monica 

lL4zen@? 

2 A Yts, sir. I do now. 

3 Q Allright. Andhowisitthatyouknowhcrnow? 

4 A FromtheTVreportsandIhadseenhexonoccasion 

5 attbeWh.iteHouse. 

6 Q Allright. !Soyouhadseenberonocca&n. I 

7 takeittkxnyour answuthatyoudidn’tcouoectthingsin 

8 yourownminduntilyousawthepublicity~the 

9 Monica Invinsky and Resident Clinton matuS 

0 A Ibat’scnxxt. 

1 Q Irepresenttoyouthatthatpublkitystartedon 

2 or about Wednesday, January 21,1998, all right? several 

3 monthsago,inthisyearthatwe’renowin. Whmdoyou 

4 thinkthatyoufifitsawMoniczlLcwins@whikyouwere 

5 stat.ionedattbeWhiteHouse? AndIunkstandthatthisis 

Pine c - Paop R 
1461 

. 

Inns: Grmdhyl%oceab 

r gs Mull 

page9 

1 an approI&tion. 

2 A Iwaaldsayitwouldprobablybetheendof’96or 

3 beginn& of ‘97. I’m not really even sure. 

4 Q m’right. Lctmerepreseattoyousonxotkr 

S facts8adtktisthatIvfonicaL%&4n&yworksdfvstsan 

6 intern at tk White House f+om early July of 1995 through 

7 approximately the middle of April of 1996, okay? Wkn sk 

8 wastih?msfaredtothePentagon,tkDepartmentof 

9 Defense, in virginiE$ all right? 

1 0 A &&. 

1 1 Q U>battin&nneasagauge,canyouklpus 

1 .2 withdating8pproximatelythef~timeyousawher7 

I 3 A I’msunzitWOddbesamewhert inthemiddleof 

1 4 thattim&amethatyougaveme,thea. Justinpassingin 

I .5 theh&~ytnth&StWii. 

I 16 h4R PAGE: All right. By the way, my colleague is 

I .7 nowwithmetomyrighSMaryAmxWirth. 

I 88 MS. WIRTH: Hi. 

I :9 THEWITNESS: Hi 

L 1 10 BY MR. PAGE: 

; !l Q ~w,msyouworlriogi.ntbehstw.wtkmyoUf.i 

2 !2 lXtOrSaWMOlli~Lewinsky? 

2 !3 A Yes,&. 

2 !4 Q Tellusabouttha~ Wknewereyoupo&ioned? 

2 !5 Whatwasyourjobbackthen? 

Page 10 

A My position was the special operations section. It 

was what they call a tour whip which basically means you’re 

tksupavisar’srighthaadman. Wemalcesurethattoursare 

opeaatedinanom&timelymamxr. 0ff1cer.s are where 

tky’l.esupposedtokwhenthey’resupposedtok. Andthe 

onlytimcIcould xmemkrsekngherwasjustinpassingiu 

thehallway. Inevextalkedtok?thatInCall. 

Q%idskappeartoyoutobeanemp~oyeeattk 

9time? 

I 0 ‘A* Skhadapassthat-Iknow someonesaidtbatshe 

1 1 wxsanewintem,krandhowmanyhundredothers. 

1 2 Q Allright. Soyounevertalkedtohe~? 

1 3 A No,sir. 

1 4 Q Andonhowmanytimesdidyousxher, 

1 5 approximately? Including this one we’ve just discussed 

1 6 A W&,thostwoandtknj#oneOtbatime. 

1 7 Twoorthne,I’dsay,togetkr. 

1 8 Q Sohvoorthreetdal. 

1 9 ARight. 

2 10 Q -WeretheyahKaysintheEastWing? 

2 :I A No,sir. ‘IheoneothertimethatIsawkritwas 

2 :2 apparentlyafterskhadlefttheWhiteHouse. Itwasa 

2 13 Satur&yusundayaftemoonandIwsworkinginthe 

2 :4 mansion. Another officer phoned me and I don’t recaIl what 

2 ,5 it was. It wasn’t relevant at that time. Said that there 

L 

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1 wasayoungladyonthewaytowardsme,hadapass. 

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Q Allright. Andwhucwassheuseringtbatday? 

A Ibe&vesbeenteredthroq&theeastappointnxnt 

gate. 

Q And you said a Saturday or a Sunday you believed, 

correct? 

A Yes,& 

Q Whydoyouhavethatbelief? 

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A We&because-I~tbattbetourShad 

finishedandIwasonanotkrass@nxntandIjustknowit 

was a Saturday or Sunday and I just can’t nxall for sure 

which day it was. 

Q Whattimeofyearaadwhatyear,inyour 

estimatioal, was this pa&&r visit? 

A ‘IbeonIythingIknew,itwasafteshehadbeen 

dismissxif+omtbeWhiteHouse. Icwldn’tgiveyouanexa 

darewtime. 

Q Allright WhichI’verepresxtedtoyouwasApril 

of ‘96. 

A Iklieveitwaseitherintkspringortk 

summer,youknow,itwasniceouffromwhatIcanrecall. 

Q So you’re saying it could have been summer of ‘96? 

A Yes,.&. 

Q Or it could have been spring or summer of ‘97, 

I comt? 

B A No,Idon’tklieveitwasthatlate. Ibelieveit 

9 wasrightafter-in’96. 

0 Q AU right. Soyou’redoiiapost-to-post 

1 observation of kr. You’re the frrst person to - 

2 A No,Iwasactuallytbesecond 

3 Q You’re tk second? 

4 A &xxheenteredtkgate,she~tpastanother 

5 Offlccr. who then called me. 

Page 1: 1 

Page 9 - Page 12 
1462 

Page 1: 

1 _Y. 

2 And then I called auotbex off&r. 

3 Do you Yecall who called you or wllo you Gilled? 

4 I have no idea. 

5 No idea? 

6 No, sir_ 

7 In any event, you lamed from the officer at the 

8 east appointment gate that apparently this is someone who is 

9 caminginforanappointmentanddidIhearyousaytbatthis 

1 0 wastobringsomepapers? 

1 1 A Iddt~cxactlyWbatthertasoning~. TO 

1 2 thebcstofmy~~n,itwastopickup~papersca 

1 3 dlDpSOIIlC&R3pXSOffOr -somewheovcrinthewestwing. 

1 4 lllat’sthebestthatIcandthat. 

I s Q &tellusI 6 A Anditwasn’tuntilafterIactuallysawberface 

I .7 onl’VthatImadctbzcom&ionwitbtbcnameandtbcfacc. 

I .8 Q wbenyousawher,doyOUECOkCtwhetberCRaot 

I .P sbchd8IlyppUSwitllhd 

2 !O A No,Idon’tbelieveso. 

2 !I Q Allright. Doyou~howsbewasdraedorif 

2 I2 ShewaSwitb8Xlybody? 

2 I3 A No, she was alone. I couldn’t tell you how she was 

2 !4 

2 !5 Q Wbcredidsbcgo? 

Page 14 

I A Iwatchcdberfrommypostinthcmansiongoing 

2 acrossthccoLmnadeoutsidctheRoseGardentothenextpost 

3 andtbat’sasfarasIsawher. 

4 Q Andinwbichdirectionwasshcgoing? Was& 

5 headingfromeasttowest? 

6 A Yes, sir. 

7 Q Wasshegoiagintbegeneraldin%tionoftbe@al 

8 Offii? 

9 A Wcll,tbcOvalOfficeisinthcWcstWii. Idon’t 

1 0 knowiftbat’swberesheendeduporshewenttosomebody 

1 1 elsz’s office. 

1 2 Q Didyouscchcragaintbatday? 

1 3 A No, sir. 

1 4 Q Wbattimc-doyouknowifyouwcntoffsbifttbat 

1 5 day? 

1 6 A Yes,sir. Idid. 

1 7 Q Do yw know what hours you routinely worked on tbc 

1 8 wakendsmaingthattimepniod? 

1 9 A 

2 !O 

2 

2 

2 

2 

2 

!I_‘\ 

2 Q WbattimcdoyoutbinkthatyousawMonicaLAvinskj 

:3 onthisday? 

:4 A I think it was early afternoon, l:OO, 1:30. 

:s Q Beforctbeendofyourshiftat2:3Op.m.? 

In re: Grand Jury Procabgs MUll 

1 

Pagem August 13,1998 

Page 15 

1 A &s,sir. k,sir. 

2 Q Doyournaemberqthingaboutbcrthatdayin 

3 particulaf? 

4 A No, sir. 

5 Q Howshewasdress&anythingliketbat? 

6 A No. 

7 Q Andit’syourrecollcctionsbcdidn’tappearto 

8 haveanyftieorpaperswithbef? 

9 A NottbatInxall. 

0 Q Isitfairtosay,tbougb,tbatyoucan’texcludc 

1 that? Inotkwc&thatskmayhavebadpapcrs? 

2 A ~cussmc. Iwoub’tswearonewayctrtbeotber 

3 wbefeshcbadpapm0rllot. Icouldn’teven renxmberifshc 

4 wascanyingacmitatthatpoin~ 

5 Q Ailright. You&cb’tseeberafbxtimtuntilthe 

6 publiciw 

7 A Yes, sir. ‘bt’s xi&. 

8 Q Sohowmanytimestotaldoyouthinkyousawln? 

9 A ‘hvoathfceattbemost. 

0 Q Andbutforthisoccasiontbatwe’vebeaxtalk& 

1 about,tbCotbertwowcreintbeEastWii? 

2 A Yes,sir. 

5- 

Page lb 

I A_ 

2 Q--I 

3-T=--- 4 

:,^“““:’ 

7 fi’ 

8 

9 bus:=- 

0 THEwlTNE!ss: - 

5-- 

6 THEwYfmEss: v-_j 

7 A JUROR: w-4 

BW 

9 THE WITNESS: 1-w 

3 ARJROR: Ibesthatt&tohighlevelapprovalor 

I doyoudotbatonyourown? 

5 THEWlTNES: No.normall~weamdotbatonour 

Page 13 -Page 16 
Page 17 

1 owu. 

2 AJUROR: Isee. Tbnkyou 

3 MR. PAGE: Would you pkasc acux him? 

4 THE POREPERSON: Mr. Housdxhkr, you an cxcusai. 

5 Tbadcyou 

6 MR. PAGE: Thank you. 

7 (TbZWitXlCSSWSCXCU!d) 

8 (whcrarpm, at 2:07 pm., tbc taking of edin~~~y 

9 intbzplwaAceofefullqwaumoftkGrandJurywas 

0 conchdod.) 

1 ..*** 

. Inre: GmndhmyPmceedmg 8 

1463 

Multi-Page= August 13,1991 

1 

Page 17 - Paee li 
1464 
1465 

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

- 1 - 

OFFICE OF THE INDEPENDENT COUNSEL 

Date of transcription 3/3/98 

MARK HUFFMAN, Office Manager, Office of Public Affairs, 

U.S. Department of Defense, was interviewed in the offices of the 

Pentagon General Counsel. BRADLEY WIEGMANN, Pentagon Deputy 

General Counsel, was also present during the interview. HUFFMAN 

was advised as to the identity of the interviewing Agents and the 

nature of the interview. He provided the following information: 

HUFFMAN advised that he had nq_involvement in the 

hiring of MONICA LEWINSKY as the Confidential Assistant to 

KENNETH BACON, Assistant Secretary of Defense for Public Affairs. 

HUFFMAN was supervised by BACON's deputy, CLIFF BERNATH. HUFFMAN 

advised that LEWINSKY did what she had to do to get her.job done. 

HUFFMAN had no conversations with LEWINSKY about any alleged 

relationship she may have had with President CLINTON. LEWINSKY 

did mention that she had given President CLINTON a tie. 

President CLINTON may have worn the tie in a television 

appearance. HUFFMAN saw LINDA TRIPP on a number of occasions 

talking to LEWINSKY. LEWINSKY frequently talked on the telephone 

to her friends at the White House. HUFFMAN advised that he does 

not recall LEWINSKY leaving work early on December 19, 1997. 

HUFFMAN did not have any conversations with LEWINSKY about 

seeking employment in New York. HUFFMAN recalled that some time 

in early-December 1997, LEWINSKY left the office crying and 

stated that she had to take care of something personal. HUFFMAN 

advised that the last day he saw LEWINSKY was on December 23, 

1997. HUFFMAN was on leave during the holidays. 

HUFFMAN provided the following background information: 

Home address: 

Home telephone: _L 

Date of birth: 

Employment History: Active Duty Military 

August- - _ 

Retired: 

Rehired one month later 

in the Public Affairs Office 

at the Pentagon 

Investigation on 2/27/98 at Washington, D.C. File X 29D-OIC-LR-35063 

_ Dart dictated 

=b 
1466