1087 

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

- lOFFICE OF THE INDEPENDEhT COUNSEL 

Date of nanscription Z/4/98 

URSULA "URSIE" FAIRBAIRN, Execuzive-Vice President, 

Human Resources and Quality, AMERICAN EXFRESS, INC.(AE) was made 

available for interview by_AE Corporate attorney, MARK BELNICK, 

at the AE Financial Center Tower, 200 Vessey Street, New York, 

NY. BELNICK and his associate JOYCE SZUYUX HUANG of the law firm 

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

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

~11 persons present were advised of the purpose of the interview 

and the official and personal identity of Investigator BASTIN 

and FBI Special Agent PATKUS. FAIRBAIRN thereafter provided the 

following information. 

On December 10 or 11, 1997 FAIRBAIRN learned that she 

had a message indicating that VERNON JORDAN had called and would 

like for her to return the call. FAIRBAIRN called JORDAN at 

telephone number !- JORDAN said he would like to send 

FAIRBAIRN a resume of a talented young lady and see if she 

matches up with any company openings. FAIRBAIRN agreed to talk 

to her and JORDAN said he would send the resume. FAIRBAIRN 

thought he was going to send the resume by fax, however it 

arrived by Federal Express. 

FAIRBAIRN stated that it was no: unusual for board 

members or other company officers to recommend talented people 

for employment with AE. 

FAIRBAIRN said JORDAN did not mention BETTY CURRIE or 

any other WHITE HOUSE official in the telephone call and 

additionally there was no perceived pressure .exerted by JORDAN. 

JORDAN has made another employment recommendation approximately 

two months ago. 

After receiving the cover letter and resume from 

LEWINSKY, it was a few days before LEWINSXY called. FAIRBAIRN 

believes she called on December 15;- 1997 and the conversation 

lasted 7 to 10 minutes. LEWINSKY was cordial and pleasant and 

expressed a desire to obtain employment in the areas of 

Communications or Governmental Relations. FAIRBAIRN concluded 

that both of these areas were under THOMAS SCHICK and she 

therefore informed LEWINSKY that she would check with him in 

order to get the process started. FAIRBAIRN recalls LEWINSKY 

Investigation on l/29/98 af New York City, NY Fiic I 29D-LR-35063 
1088 

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

29D-LR-35063 

Continuation of OK-302 of Ursula Fairbairn ,on l/29/98 .pape 2 

mentioning working at the Pentagon and the WHITE HOUSE but does 

not recall discussing in detail her work experiences in this 

phone call. 

FAIRBAIRN wrote a note to TOM SCHICK on December 16, 

1997 telling him that the attached resume was forwarded to AE by 

VERNON JORDAN and that HARVEY GOLUB, Chairman of the Board (COB), 

=, is aware of the recommendation. FAIRBAIRN stated that it is 

her policy to always advise the COB when an employment 

recommendation comes from one of the members of the board. 

FAIRBAIRN recalls that she saw SCHICK in the building 

on the 16th and mentioned the resume to him, he indicated that he 

would be in Washington the following week and asked FAIRBAIRN to 

call LEWINSKY and give her his telephone number so that maybe the 

interview could be done while he was in Washington. FAIRBAIRN 

called LEWINSKY and gave her SCHICK's telephone number. 

FAIRBAIRN remembers receiving a "thank you" letter from 

LEWINSKY and kept it for a period of time next to her telephone 

just in case JORDAN called and inquired about the progress. She 

didn't receive a call and she didn't follow up with any other 

contacts. 

FAIRBAIRN then recalls reading about the controversy in 

the newspaper. She has not been contacted by anyone at the WHITE 

HOUSE concerning LEWINSKY nor has she been contacted by JORDAN 

since the controversy received publicity. 

FAIRBAIRN is described as follows from observation and 

interview. 

NAME: Ursula Fairbairn 

SEX: Female 

EMPLOYMENT: American Express, Inc. 

TITLE: Executive Vice President, Human Resources 

and Quality 
1089 

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

29D-LR-35063 

Continuation of OK-302 of Ursula Fairbairn ,On l/29/98 . Page 3 

TELEPHONE: 

, 
1090 
1091 

Page 3 j 

InRe:GrandJuryProcecdings Multi-Pitgem Friday, July 17,1998. 

UNITED STATLS DISTRICI -‘: 

FDA TNC DISTRICT OF CDIAnmIA 1 PROCEEDINGS 

---------e------x 2 whereupos 

I" BE: 3 ROBERT C. FERGUSON 

GMND .NnY pBDcuDI*Gs : 4 wascalIedasawitnessand,afterhavingbeenfirstduly 

5 sworn by the Fomperson of the Grand Jury, was examined an 

-------v--------i 

6 testified as follows: 

axnd Jury - “0. 2 

United SUUV Dl,Uict COUU. 7 EXAMINATION 

for the Disuicr Of co1tnbia 

3rd L coasutUtlorl, Y.Y. 8 

ll~~hinqtaa. D.C. 20001 

MR. PAGE: AlI right. Mr. Foxperson, may I begin? 

f - .* 

Friday, July 17, 1999 

9 

. . , 

THE FOREPERSON: Actually, it’s Madam. 

me t*stlmny or aoDE c. muaEoN “.rn uli*n rn 

0 MR. PAGE: I’m sorry. Madam Foreperson, may I 

th. prm..na or . tu11 quonn or cruld Juq 97-4, upuuled 

1 be@? 

an Dscanber 5, 1997. -ncln9 .t 2~43 p . . . . tsrore: 

2 THE FOREPERSON: Yes, you may. Thank you. 

-T .I. BIITB‘W 

3 MR. PAGE: Thank you 

SoIawN *1BmBEBG 

JACKIE n. BCNNCTT. JR. 

4 I’dlikethe~toreflectthatwehavea 

5 quorum and, is it true, Madam Foreperson, that there are no 

nAnY NINE YIATH 

EmAND .I. PACE 6 unauthorized individuals in the grand jury room? 

Associ~tr Ind.pend.nt counr*1 

ortic. 0r xndqmdenr counmd 7 THE FOREPERSON: Yes. 

1001 PeM*ylvuli~ Av*mm. Y.W. 

suit* 490 North 8 MR. PAGE: Thank you. 

Nashlnqton, D.C. 20004 9 BY MR. PAGE: 

0 Q h4r.Faguson,mynamei.sEdwardJ.Page. Ihave 

1 the honor and privilege of working for Mr. Starr, who is the 

2 Independent Counsel in regard to certain matters. Do you 

3 understandtbat? 

4 A Yes,sir. Ido. 

5 Q Tbankyou. T%isiswhat’scalledagrandjuryand 

e.pc 1 Page 4 

CONTENTS 1 youareinfrontofagroupofcitixnsheretoanswersonz 

2 questionsthatIwillbe&ingyou. Allright? 

WITNESS: 

Robert c. F.rpumon 

GRAND J”NY CNNIBITS: 

No. RF-l se-tk or Y.S~ nin9 

9.9e 

3 

22 

3 Tkereisacourtreporterpresent. He’sseatedto 

4 your right. That’s not a microphone. He is recording what 

5 y&-e saying and what I’m saying and what questions the 

6 grand jurors might have of you, should they have any. 

7 A Ye&sir. 

8 Q Do you understand? 

9 A Ye&sir. 

0 Q All right. Before I ask you the questions that we 

1 have for you I need to explain some things for you. If at 

2 any time you have a question about those, please interrupt 

3 because’it’s easier to deal with questions when they arise 

4 ratberthanifyousavcthem. 

5 Fii of all, any things that would prevent you 

6 from testifying here today? For example, you don’t have any 

7 hcaringpmbiems? 

8 A No, sir. Ihaveno reason. 

9 Q All right. Do you understand whatwe’retaking . 

0 about today? You’ve been following so far? 

1 A Ye&sir. 

2 Q All right. Do you understand, number one, that 

3 whatgocsootodayinf~tofthegrandjury,thcqutstions 

4 andtbeanswus,amsecretunderlawandtbatnoneofthe 

L 

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Page 

I thegrandjury? 

2 A Yes, sir. I understand. 

3 Q The one person I left out is you and that is you 

4 have a right after you leave here to sham with people what 

5 happened hem today, should you choose. Do you understand 

6 that? 

7 A Ido. 

8 Q Do you understand by my visiting with you about 

9 this law that I’m not suggesting in any manner what you 

0 should do later on with regard to that right? 

1 A Yes, sir. I understand. 

2 Q Do you understand that you can speak of your own 

3 free will to whomever.you choose? 

4 A Yes, sir. Ido. 

5 Q Under the law, you have certain rights before your 

6 testimony is given in front of a grand jury. Do you 

7 understandthat? 

8 A Ido. 

9 Q All right. I want to read to you now some of those 

o rights, making sure that you understand them before we go 

I forward. Okay? 

2 A Yes, sir. 

3 Q The first right that I want to tell you about is 

4 more of a general nature, to tell you what this is about, 

5 and that is that the grand jury hem is conducting an 

paget 

1 investigation of possible violations of federal criminal 

2 laws involving whether Monica Lcwinsky or others suborned 

3 perjury, obstructed justice, intimidated witnesses or 

4 otherwise violated federal law, other than a class B or C 

5 misdemeanor or infraction, in dealing with witnesses, 

5 potential witnesses, attorneys or others concerning the civil 

7 case Jones v. Clinton. All right? Tbc grand jury is also 

3 investing other related matters. Do you understand that? 

2 A 1 do, sir. 

1 Q Do you understand that you may refuse, 

I’ Mr. Ferguson, to answer any question if a truthful answer 

! to it would tend to incriminate you? 

1 A Yes, sir. I understand that. 

i Q That’s commonly called your Frfth Amendment right. 

5 A Yes, sir. 

5 Q Do you understand that? 

1 A I do, sir. 

$ Q Anything further that you do say may be used 

P against you by the grand jury or in a subsequent legal 

) proceeding. Do you understand that? 

I A I do understand that. 

b Q If you have a lawyer, the grand jury will permit 

I you a reasonable opportunity to step outside the grand jury 

I room to consult with that lawyer if you so desire. Do you 

i unckrstand that? 

Page7 

1 A Iundcmand. 

2 Q Do you have a lawyer? 

3 A No, sir. 

4 Q All right. You seemed to hesitate when I asked 

5 that. 

6 A Well,thereasonbeingisthcrcwemsomeissucs 

7 earlier regarding some of the security information tbat may 

8 be asked and, in that regard Justice has picked up that 

9 proceedingforussoifinfactthatweretobecomean 

0 issue, I would like the opportunity to confer with them. 

I Q All tight. That’s the Department of Justice. 

2 A -l-hat’s correct. 

3 Q Is there an individual with whom you’ve been 

4ckaling? 

5 A AnnMkiamn. 

6 Q Doyouunckrstandtbatbesidestbeitemsthat 

7 you’ve mentioned, the only rule that you can invoke here to 

8 avoid tcst@ing is a rule that governs privileged 

9 information? For example, the marital privilege, the 

0 attorney-client privilege, the psychologist or psychiatric 

1 privilege? 

2 A Yes, sir. I un&mtand. 

3 Q All right. ‘There is no, as you’re probably well 

4 aware by now, a protective function privilege. 

5 A I understand that. Yes, sir. 

Pagta 

1 Q Do you understand that? 

2 A I do. 

3 Q And, in fact, that’s why you’re now here, correct? 

4 A Yes, sir. 

5 Q Do you understand that the law makes a distinction 

6 between being a target of a grand juty investigation and a 

7 subject? 

B A Yes,sir. I&. 

3 Q Allright. Ireprescnttoyounowatt.histimc 

3 that you are a subject of this grand jury investigation 

I becausethatisdefinedas somatWhoscconducf~ 

2 whostactionsintbcpast,arcwithinthcscopcoftbcgrand 

3 jury’s investigation and, in your situati~ I represent to 

I youtbatit’sinabroad~intksensetbatyoumaybea 

I faetwitnesstosomethingstkgrandjuiyislookingat 

5 un&thatmandatethatIteadearlier. DoyouuIl~ 

1 that? 

% A. Yes,&. Ido. 

P Q Allright. ~youundemtandthatyoubavetote~ 

1 thetruthbemtodayandthatyou’vetakenanoathtodo 

I that? 

! A Ido. 

I Q All right. Do you undemtand that I’m going to be 

I asking questionsand you will ensulaandthcntbegrandjury 

i willbaveahopportunityaswelI8smyeolleagutstoask 

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Y a.“. UIOYY emmA, a ruu-?wvMaem *.I-” 1 V” 1 *run,, rru, a ,, 17iTo 

page9 Page II 

1 youquestionsandto answer? Sort of like playing tennis: 1 Q Those are the only two official categories that 

2 I serve you a question and you volley back with an answer. 2 the Depwtmmt of Justice recognizes, but there is an 

3 Doyouundastandthat? 3 unofficial -- and a subject is basically anybody who has 

4 A Ido. 4 information relevant to tk grand jury. Do you understand 

5 Q Have you ever testified before? 5 that? 

6 A &fortagmudjUy? 6 A Ido. 

I Q Or in any situation. 7 Q Tberc is an informal designation that has grow up 

8 A Oh. Yes, sir. 8 among prosecutors and deft attorneys of target, subject 

9 Q underoath. 9 and witness. Wi@in that category, you would be considered 

0 A Ye&sir. 10 witnss. Do you understand that? 

1 Q Soyouknowwhatthisproeessis. 11 A Ido. 

2 A Yes, sir. 12 - MR. WISENBERG: All right. 

3 Q All right. Do you have an understanding right now 13 Pardon me for the interruption. 

4 as you sit there about whether you should volunteer 14 BY MR. PAGE: 

5 information or just answer tk questions as they’re put? 15 Q Okay. Before we get star%& do you have any 

6 A I will answer you as truthfully and fully as 1 can. 16 questions about the topics that we’ve discussed? 

7 Q All right. In other words, I’m telling you that I 17 A No, sir. 

8 wilI probably need your help along the way in bringing out 18 Q All right. Where doyot~ live? 

9 all of the information and I would ask you to volunteer umap: 19 A I live in Davison, North Carolina 

0 you think it‘s appropriate. 20 Q And how long have you worked there? I’m sorry, 

1 A IeanassUreyou,sir,thatIwiI.l answer you fully 21 Iivedtbere. 

2 and to all of the information, tbe extent that I have. 22 A Lived there? I’ve lived there approximately hvo 

3 Q Asapartofyourobligationtotellthetruthhere 23 and a half months, sir. 

4 because you’re under oath, do you understand that you can’t 24 Q Were you previously employed or do you now work? 

5 without basis say you forget or you can’t mnemberwhenin 25 A Yes, I was previously -- 1 do now work, but I was 

-. 

Page 10 Page 11 

I fact you can? 1 previously employed by the United States Scent Service. 

2 A Ob I understand. Yes. sir. 2 Q For how long? 

3 Q AU right. Do you understand. finally, that th: 3 A Approximately 14 years. 

4 oath that you took carlicr makes your statanem Iwe if tky 4 Q Your last assignment was where? 

5 are fake subject to tbc penalties of pajury and obsuuction 5 A With the Special Sezrviees Division of the Seeret 

6 of justice in some fass? Do you undastand that? 6 Service and prior to that the Presidential Protective 

7 A Yes. sir. I do. 7 Division. 

8 Q Doyouundasrandthattbosctwocrimsarc 8 Q All right. Can you tell thegrandjury 

9 fclonics punisbabk by up ta five years in jail and a fine? 9 approximately tbe timeframe that you worked or that spanned 

3 A Yes, sir. 10 your service with the protective detail? 

1 Q All right. All right. I wouldaskyoutospuk 11 A With the protective detail? Approximately, and 

2 loudly so that the woman inthcfarkftofthisroomcan 12 thest are approximations, sir, late 1994 through January of 

3 hear you as well as my colkaguez and tk court rcponcr and 13 ‘97. 

4 the foqcrson. Do you bav~ any problan with that? 14 MR. WISENBBRG: Pardon mt just a minute. 

5 A No, sir. 15 BY MR. WENBERG: 

5 h4R. WISENBERG: Ed, pardon me just a minute. Can I 16 Q Could you state your name for the record, pti? 

7 clarifjJ one thing? 17 A &tainly. It’s Robert C. Fugusa~. 

B MR. PAGE: Yes. 18 MR. WISENBERG: I’m sorry. 

3 MR. WISENBERG: My name is Sol Wisenbag Im ’ also 19 BY MR. PAGE: 

1 with the oftice of Indcpcndait counsel. 20 Q Allright. Goabeadwithyourdamagain. 

I BY MR. WISENBERG: 21 A Approximately late 1994 until early 1997. 

2 Q Mr.P~mca&maitoyouthccatcgoricsoftargct 22 Q Andthosedatesarethedatesthatyouwez 

3 and sub&t and said that you were a subjox. Do you I-O@ 23 assi&ed to the pre#ential proteetive &ail? 

4 that? 24 A Yes, sir. Ihatscomt. ’

5 A Ido. 25 Q TeIIthegmndjurywbattbatis 

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In Rc: Grand Jury Proceedings 

- 

Multi--PllgCW Friday, July 17,1998 I 

Page 1: 

1 A The Ptesidattial Protstion Division is men and 

2 women who lmve had former assignxncnts rhrougbout tbc Unital 

3 States Secret Service, gamdly on duty betuxen set and 

4 wyavs,aadyouarr:choscnOrarrassipnedtoadaail 

5 that would guard. in tbis case tk Residatt of tk United 

6 States for a 24-hour basis. You’re guxaally tkte 

7 W - dqaxhg on your promotional considwtions. 

8 you’re guxrally on that detail approximately four years. 

9 Your responsibilities would be the obvious 

0 protection of the President of the United States. which - 

1 has many iaats. You’rt going m hflvc a working shifi 

2 of individuals which are the four to five to six men and. 

3 wonm that you see around the F’rcsidcnt at any one time. 

4 We have various functions which is our i&ligmce 

5 community and also what wc call our advance function, which 

6 are those that go out in advance of the Resident and tbz 

7 First Lady and obviously Cbelsar in qards to tk United 

8 States and prepare for tkir coming to a particular location. 

9 Vay ekmentary. that’s what your assignment would 

0 k for that period of time. 

1 Q All right. During the course of your assignmatt 

2 fromlatc’94tocarly1997,didyoumactapasrmbythc 

3 name of Monica Lewinsky? 

4 A I know who Monica hwinsky is. I don’t know bu 

5 monallv. no. 

3 

Page 14 

1 Q You never said hi to her or met her where you were 

2 introduced? 

3 A No, sir. Not introduced. I may have spoken to her 

4 on an occasion I’11 he happy to discuss, but I do not know 

5 her personally. 

6 Q So your testimony is you never met her, but you 

7 know her. 

6 A That’s corrtxt. Yes. ‘Ihat’s correct. 

9 Q How did you fvst know her? 

0 A ‘Ihe dates in the testimony I’m about to give you is 

1 the absolute best of my recollection. My fim encounter 

2 with Monica Lewinsky was, to the best of my recollection, the 

3 winter, I believe it to be in December, of 1996. I tzcall it 

4 being during tbe wk. 

5 Irecallitbeingonanaverage-Idon’tlamw 

6 what day of tbe week, but I would expect it was Monday 

7 through Friday, one of those days. It was not a weekend and 

9 therearereasonsthatIrecallthafbutitwasduringtbe 

3 normal course of business and I was working a protective 

1 shift which are the men and women that are around tlx 

I President for that period of time. 

2 Iwasonapost 

I-“TbcidcntoftbcUni~Statswasintbc 

2 Oval Of&x at that tire. 

3 MostofthepeopkwhoworkintkWestWingofthc 

4 White House am commonly known to all of the agents. We 

5 work with them on a daily basis. those comings and goings. 

6 That am those presidential appointments who we do not know 

7 that wc pay more dirst attmtion to because tky are not 

8 immediately mcognimbk to us and we would know tkm. 

9 Obviously to @ into those locations, they’ve bad 

0 togotbrougbmany~uritycbeckpointsandtkyareissueda 

1 passthatttqwouldwaro4wiouslytokintotbosc 

2 paIticularaKas. 

3 TbemasonIdidnotknowwhoskwas.skcame 

4 fromtbcballweypasttbeOvalMficcwhichwouldbt5 tbeoffiasbousedwouldbavcbemdowntbeball, 

6 Mr. Stephanaopoulos’ ofIke tk vice presidential office. 

7 ThcrrasonbeingtbeEcisastainmllthatcomcsupintothat 

8 levelandIdidnotknowh3rs.Lewin&yatthattimeandrbc 

9 onlysCasonIEcalltba~andIcanrccoUntthisforyo&is 

0 thatIdidnotrecognizehufaceandIimmediatelykoked 

1 downforhapassandfoundittobepmper. 

2 IkllowthatMrs.Lcwinslry-Isnayllavesaidbello 

3 orImayhavcsaidacuscmc~wouldhsvcbrmsomdhing 

4 that= commonly would hsve done ,m stop that person for 

5 iuxgnition purposes, just for a moment, just to make sure 

Page 16 

1 that eveqding is frnc before you’re actually going into 

2 wbat we considered to be tlx West Wing suitz which would 

3 house Mrs. Currk, the Prmitht’s pawnal sammy, and 

4 Mrs. Nancy Hernmich who is the Pmsidcat’s appointments 

5 secretary. 

5 Now, this is not into tk oval itself, but just 

7 into that suite of offkes outside of the oval but are 

3 adjacent to. 

J IdobekvethetIwouldhaveaaidsom&ingto 

1 kr,topauscforamomcnt. Wcwmldscetkpassandtkm 

I was-undcrareasonabk~wewouldbaveallowxdtbem 

. 

2 to go into that suitt of Offlica. 

s 1kmwthstMts.Lehskywartintothose0ffi 

4 and+fulthL7thMtha~IhadnootbudCal@s~yiewod 

5 Mrs.LewbIcyinanyway. 

5 Wchavearotatkmalabifktimtwould-you’renot 

1 goingtostandinmkcatiaifculmumandkmaatatime. 

1 Wemtatetboseassignmattsr0y0uhavesomadowntimc,so 

3 youcatlgetoffyourfceLlwpefu&,particularlyi.ftbe 

1 Presidalt’s in the Oval offi for a kxlg period of t&k. 

I SoIviewalMrs.Lminslcygointothcoffice.at 

! tbattimcdon’tknowwhaesbzwattinsidethcoffkeand 

I lwassubsegtxsnlypuskd-ImeankfttbatporSwas 

1 repbaa.lbyanotkagalt#luKl1~ttoanotha~xl 

i that’s my fort QlcountQ with h4m. Lewinsky at all. 

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I Q What time of day was this. rpproximatdy? 

2 A It was during daylight hours. during a normal 

3 workingdey.whichisgcnaallyninctofrvtattbcWhiL 

4 House, but, 0th~ than that, I have no specific recollection 

5 ofwbattimcof&yitwouldbavebcm. 

6 Q Doyousuncsnbertkagenttktrcplacrxiyou? 

7 A I don’t, sir. 

8 Q SowhaedasMs.Lwinskycomefmmagainthis 

9 by? 

0 A W&skea&from-whicbwouldkwzsttocast, 

1 butshecamefromahallway-skwouldhavecomeup,I 

2 asslmqdepaldingifsheinfacthadcomfmmwtrxvask 

3 wascomingfrmn.whichisnotunusuaZbutsbccamfnnna 

4 hallway which would have been t%nn like tk vice presidratial 

5 officcs,whicharrlocatcdatooncadofth:ball,pasttht 

6 Oval. Off+ to whue Mrs. Currie and h4rs. Hanreich’s office 

7 wouldk. 

ii AndsoIwas-ifinfactthedoorhercisan . 

9 example. this room would have ban into tk suite. I would 

0 have ban posted approximakiy wln~ we are current@. 

1 Mrs. Lcwinsky would have come down the hall, we would have 

2 saidsomethingtokrtostop,justtom&esurcitwas 

3 appropriate, and then sk proccedod into the suite and that 

4 was my last cncoun~ with her during that period of time. 

5 Q And you believe that this was in December of 1996? 

Page 11 

1 A I have thought about this at length and it’s the 

2 best of my recollection. I’m sorry I can’t provide you any 

3 more -- because that was not an unusual occurrence for us. 

4 That’s a daily occurrence, not with just Mrs. Lewinsky, but 

5 many, many people throughout the mansion. So I have no 

6 specific recollection of the exact time that that would have 

7 taken place. 

8 Q Is it fair to say that you’ve thought about this 

9 since the publicity surrounding the Monica kwinsky matter? 

0 A Yes, sir. ‘Ihem’s no question. 

1 Q And thought about this more? 

2 A Certainly. 

3 Q And is that how you’ve come to date this 

4 approximately? 

5 A Until this story became public, I did not even know 

6 who Monica Lewinsky was pemonally. I mean, I’ve come to 

7 know her and quite honestly through seeing her on television 

8 and the breaking of this possibility of a story that I was 

9 able to connect that person with the hvo encounters that I 

0 had with Monica Lewinsky. 

1 Q Wherewassheheadedwbmsheandyousaweach 

2 other and she passed by you? 

3 A Well, actually, she would have approached me to 

4 have made a right turn, into a small hallway, by the way, 

5 inu,~tsuitewhentheyarelocatcdsoshcwwldhavt 

1 come dinxtly to us. And most people acknowledge us and UT 

2 acknowledge km, that everything is proper. And she did 

3 thatsimilzlyaadtbcnsbeprocee&dintothatsuiteandI 

4 have no recollection of anything occurring after that. 

5 Q Andtellusagainwhoisinthesuiteofoffkes 

6 thathklzwimkywentinto. 

7 A Well,BettyCurrie,whoistheRsident’s . 

8 r+ecnwy, pmmal secretary, and Nancy Hemreich, who is 

9 the Prcsidart’s appointments secretary. 

0 Now,tbereare-oftcntimes,therearemanypeopk 

1 in tkse Offlccs. ncy’n not a vuy large suite of oflice& 

2 but them’s also a television mt that’s located directly 

3 througbtbedoor,sooftentimsthemwillbeother 

4 presidmtialstafforworkersofonenatureoranotherthat 

5 amthcremutinely. Butastowhowasintheretbat 

6 particular day, I couldn’t venture a guess. 

7 MR. WISENBERG: Ed, do you mind if I interrupt fo 

8 justasecond? 

9 MR. PAGE: No. 

0 BY MR. WISENBERG: 

1 Q Ldxneaskyouaquickquestion. Assumetheoval 

2 Offtceisaclockandthereisan 11:OOdoortotheOval 

3 office. IsthatalTect? 

4 A From-- 

5 Q Well,whatI’mttyingtogetatisexactlywherein 

-. 

Page 2c 

I relation to - let’s say you’ve got Betty Currie’s &sk right 

2 outside of the oval Office. You’re awate of that? 

3 A Oh, I am. What position is that for you and I can 

4 go from there. 

5 Q That’s outside of the 1:00 door. 

6 A That’sa 1:00 door? 

7 MR. WISENBERG: Yes. 

B LetmejustshowyouaschemeoftheWhiteHouse 

9 whichwe’vemarkedasGrandJuryExhibit 1. 

D (Grand Jury Exhibit No. 1 

1 was marked for identification.) 

2 THE WI’INESS: All tight, sir. 

3 MR. WISENBERG: And what I mean by 1 l:OO, this 

Q would be l:OO, this would 11:OO - 

5 THE WITNESS: Oh, I see. You’m looking at it this 

6 way. 

7 hIR. WISENBERG: Okay. 

s THE Wll’NESS: All right, sir. 

9 BY MR. WISENBERG: 

3 Q And I want to know just simply, you said you were 

I outsidethe~st. Couldyoumadcwhemyouwaeontbis 

Zmap? 

3 A Ye&sir. 

4 Q Youcanusetbisgrearpen. 

5 A -IhisisthccolonnadeoftheWhiteHouse. Thisis 

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1 tkstandardcolonnade. ThscaTtbcdoors. Thisistk 

2 door that would typically go into tbz suite. If you draw 

3 this. this is Nancy’s offrcc, this is what Betty sits right 

4 hue. 

5 

6e ). so 

7 she would have comt down tk ballway, sbe would had to have 

8 approachal us to go into this axa. 

9 Q Okay. You arc what in relationship to Nancy 

0 Han&&? 

I A Well, acmahy, that’s not inside her offkc. What 

2 you’re going ta find is tbc cabinet room. This is actually a 

3 hallway. 

4 So this comes down - kc’s the oval. Thcy’rc 

5 going to come down this hallway, they’re goiag to take - 

6 hm’s the Oval Oft% door. 

7 She’s going to come to hcrr what tkmpost is, 

8 and then into this suite of off~ccs. 

9 Q Okay. SoIjustwantto-tbc11:OOcloorthat 

3 I’ve pointi out. assuming the Oval Office is a clock. this 

1 would be- my qucstioa to you is a2- 

3 A I can’t. 

1 Q You can (sic). 

5 A Yes. sir. 

Page 22 

I Q Okay. And by the way, this is called -- it’s 

2 Robert Ferguson. correct? 

3 A That’s correct. 

t MR. PAGE: We’re going to relabel this RF-I, Grand 

5 Jury Exhibit RF-l. 

5 (Grand Jury Exhibit No. RF-l 

7 was marked for identification.) 

8 BY MR. WISENBERG: 

9 Q And would you agree that I have changed that to be 

0 RF-l? 

1 A I would. 

2 MR. WISENBERG: Okay. Thank you. 

3 Letmejustsayoneotherthi~. 

4 BY MR. WISENBERG: 

5 Q Thisisthe-ourinfotmationisthatthisis 

6 actually a door out of the Oval Offtee which I’ve called 1:00 

7 and that Betty Ctmie’s desk would be out here and assuming 

6 that that’s correct, I just want to make sure that we get - 

9 A Absolutely. When you eome through this, down this 

3 hall, what happens is you can eome right through there and it 

1 goes right into the oval. 

2 Q Okay. 

3 A The doorway into the oval. ‘Ihis hallway, if you 

1 will,iswhatI’mtellingyouthatshehastocompastusto 

5 eome into this area. 

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1 Q Right Aad I gncss what I’m asking you is you’ve 

2 got-youbavcancnddownbczc? 

3 A Well. Betty’s offrcc is actually hex. 

4 Q -Y. 

5 A Nancy and Betty. thq’rc in lnc e oftca. 

6 Sony alom is primarily hat. But it’s almost 

7 intcrchngsabk. It’s almost intucbangcabk for the two. 

8 But Nancy Hem&h primarily sits ia this ofBce the 

9 appoinrmmts secretary. Betty’s desk which is right outsick 

0 tkovaloff--Kzdoor,isprimariIyhac.sir. 

1 MR. WISENBERG: Okay. Thank way much. 

2 THE WITNESS: Yotl’rt lbthalc. 

3 MR. WISENBERG: Pardon tbc inranrption. 

4 BY MR. PAGE: 

5 Q Itbinkdraingyonrpast answuyollsaidthatthis 

6 ~~oftwooccasioaswhacyonhadsomiaterachonwitb 

7 lHonicaLcwinsky? 

8 A Yes, sir. 

9 Q Lu’staIkaboutthtnextoae. 

0 A All right sir. 

I Q TeIlusthatoac. 

2 A Approximatelytwowuks,itcouldhsvebanthrce 

3 waksbccausewe.doa’t-tlxmwasaolhiqunusualabout 

4 thisatthc moamt I know that my next a1c0untQ with her 

5 wasonaSaturtiay. Thiswilltakcsomcaplainiag.bntI 

Page 2s 

1 thinkyou’llgetthegistofit. 

2 WewaeinthemansionoftheWhiteHouae,and 

3 altho~tbesetwobuildings,tbcrr:isthtWcstWing-an 

4 you familiar with the layout, air? 

5 Q somewhat. 

6 A ABright. ?hisistheWestWingoftheWhite 

7 House. You go down what’s called a colonnade area into 

8 whatiscommonlyrcfartdtoastheWhittHousc,whichis 

9 themansioniswhattheterminologyis~tkmansiun. 

0 ThcPrsidcntandthcFirstFamilyliveonthcsccondfloor. 

1 OnthispartieularSaturday,theRcsidaltwason 

2 thestmndfloorandasashift,tkSaxetSavicxmoves 

3 withthePmsickatevaTiwithintkamfiioftheWhite 

4 Housegramdsfiomonelocatiootoanotber. 

5 nepresideatialshiftatthattimc,whi.letbe 

6 Presi&ntisinthemansion,onthesecondfloor,takcsup 

7 postssothatweean&fendhispositionswhilconthatfloor 

8 to the best of our ability. 

9 Whenhemovesdowneitherastaimamoran 

0 elevatorandprooeedsoverintotheWestWii~wi.ll 

1 praedetkPmsiden~wewillfollowtkResi&ntin 

2 mascmableproximityuntilkti~wkmverkisgoing, 

3 kthattkwcstwiikthattheovaloflitce,kthatthe 

4 Old Exeuttive Off& building, wirmver within tk emupound 

5-. I 

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1 That particular morning. tk Rsidmt mod - 1 A time later, king it could have been 10 minutes. 

2 came down tk elevators, I do recall that. unannounced which 2 it could have been 15. within that length of time, the - 

3 is not untypical for anybody on a Saturday morning. and we 3 door as you show is which we call it the-door to the 

4 pmeeedal~totkovalOfficc,whichagain,isnot 4 Oval Offla, tbc&xsl, the President opened the door and 

5 unusnalforhim~do. 5 k says, “I’m expecting scune staffers.” I believe that is 

6 Tbatparticuhrmoming,nsopposaltotakinga 6 closetocorrect. Andksays,“Letmeknowwhenthey 

7 Wtdownth:colonna&whichistktypicalfoutcLk 7 a&e.” 

8 Resident chooses to attu tk oval, which would have km 8 I said, “Yes, sir.” And the door closed. 

9 tk 3:oO door that you’ve indicated. k.camc down insick 9 For me, maybe not other agents, but this is 

0 NwnaUykdcesthatonlyontkwa&au%,tkrcasonking 10 unusual, that k would ask us directly, but you have to 

I istkze’saooncclscintbatwingduingthstp&odof 11 realixthatasfaraswcwueconazmcdtbat&iswas 

2 time. The common staff of the White House mlly arc 12 an &announced movement, that his staff, being Mrs. Currie, 

3 grcallydiminishcdo”thcwakcndsandsokNnsintono 13 his secretary, and Nancy Hemreich were not there, they WM 

4 one. 14 off, I would assume. It was a Saturday. 

5 Sokeameinadiffereardoor.whichwouldktk IS 

6 11:OOdoortbatpa&ularday. Andkwithinthat 

And I guess k was expecting - you know, we don’t 

16 know k’s expecting, quite honestly, but it was a short 

7 particular shift obviously know tk Rcsidcnt vay well and 17 time later and obviously my posting,- 

8 kknowsusandIbaddri~tkPrcsi&n~Ihadbantk 

c 

9 Umousinc driver with our tmnsportation section for two 

0 ytars,sotkPrcsident,kmsynotknoweve@ingthxis ii: 

1 to know,+bout you, but k catahly knows you cnougb to speak 21 - 

2 to you and to say something to you. 22 WhenaladywhoIdidnotknowcamtotkOval 

3 And what was unusual that palticular day is that 23 OfIke door and ma& tk con-qmt,“ThePresidentneedsme. 

4 th:Presidartwasinagoodmmdandkwascomin%intotbc 24 And I knocked on tk Oval Offtce door, I told tk President 

5 ovalandIkppencdtokvcbacnaskcdtogotothepost 25 thathisappointmcntwasthcreandk-Ithinkknoddedor 

-. 

Page 26 

I which is known as t 

Page 28 

1 kmadesomeaffiivcgcsturetomctorealiaethatthat 

2 Now, mis the post that you may or may not have 2 wasproper. IlettheladyintotkOvalOfftce. Itkn 

3 heard of before. That is a post that is held by the agents 3 closed the door. 

4* 

5 ‘y 

*4 Andthatwastkiast-whileonmthatpost, 

5 that had any indication or -- there was nothing awry, in 

6’ 6 otherwords. Imeaqthemwasnoreasonforustofeel 

7 So I took up that post. I was in a down position, 7 thattkrewasanythingstrsmgcthathadoccurnd. 

8 which means I was in a Secret Service room, which is helow 8 Imean,!3taffersonSatllrdaysoranyothertimes 

9 the Oval Office. Its approximate size, it’s similar to the. 9 when k has meetings, certainly we’re not privy to all of the 

D size of this room hem which has a lot of other security 10 interworkings of what occurs in a presidency, so there are 

1 measures inside it, but it actually has some couches and 11 OthertimesthatthePresidtntinfacthasotherstaffnsor 

2 things of that nature where we can actually take some down I2 people that WE don’t know in fact k would k meeting with 

3 time, you know, without standing all the time. 13 foronemasouoranother. Thisokwasnotoutofthe 

4 Sowhenwekardtktraffic,Imoved,kinga 14 ordinaryasfarasIwasrXmaTkd. 

5 shift member, I moved to the Oval Off& door. And the 15 Ashorttime&erthat,Irecallit-Iwant 

6 President in fact instead of going down the colonnade did 16 tothinkitwasDeccmberkcauseitwascoldoutside,not 

7 comeinthatdoor. 17 frigidbutcold,andImcaIlwknthenextegentcameto 

B And he made the comment to me, k says, k says, 18 replace me our next post which would have normally been a 

9 “Ferg,” k says, “Did you get a haircut?” 

3 And I says, “No, sir. Mr. Ptesident.” 

1 And k goes, “Oi.= And what k meant was is 

2 that obviously the bald spot on the top of my head is 22 For our shift for that particular day, that post 

3 getting larger and that was his way of kidding with me. 13 wasaotkldandtkmam-we~tkmoccasionallyfor 

1 So k went on into the oval at that time and he closed 24 one reason or another so that post was not h&g utiIii at 

5 the door. 25 thatperiodoftime. 

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1 My next post would have b&n what’s calkd E-5 and 

5W 

6 WbcnIk?-tmy~osLIhuniallywcntdownto 

7 what’s cam I’m giving you a lot of acronyms, but 

1 0s Ipickedupanova-coath~,backupsome 

1 1 stairs and pmcadcd outsidcto tbc- Bccausc I was 

1 2 gone for - baausc I was gone for a couple of mioutcs. the 

1 3 agent who I was replacing hurriedly left to go to bis nact 

1 4 assig~~~enf bccaust it was vay cold. and I took up tbc - 

1 5 position. 

1 6 Ibadbcaniooradiotraff~ciolrgardto 

1 7. prcsidcotial movanalts. - 

1 8P~~IdidloOkintotheOvalOff~icetosawtnt 

I 9 tbcPrcsidcnt-iofactifbcwasstillintbeovalaadto 

2 0 su his proximity tbae. 

2 1 Idid~tbePresidcntandIdidsccMrs. 

2 2 Lviosky. Wbat I saw was tbc Prcsidcot and Mrs. Lcwiosky 

2 3 .pmcadiog into an area commonly rcfirnd to by tbc agents as 

2 4 the study. Tbc door was tbcn closed. 

2 5 Fortbcrwnain~oftbattiodoftimctbatIwas 

II 

1 

1: 

1: 

11 

1: 

II 

1’ 

1: 

I! 

2( 

2 

2: 

2: 

21 

2: 

Page 30 

1 on that particular post, I did not see the President nor did 

2 I see Mrs. Lewinsky. 

3 I was subsequently pushed off that post in 

4 approximately 30 - within the 30minute time period and I 

5 don’t recall this exactly, but I do recall -- I mean, what I 

6 do recall is being pushed from the post. 

7 Our next reasonable post would have been down into 

8 the ) area where it’s very warm because it’s very cold oul 

9 them and I am assuming at that stage that I went back down 

D tow I was off my post, and I had never seen Monica 

1’ Lewinsky again except when the television story came out. 

2 Q Before the last segment of your testimony you 

3 seemed to delay or hesitate for a little bit. What was that 

4 about? 

5 A IwantedtomakesurethatIgiveyoutheabsolute 

6 accuratetestimonythat1canRxallbeeauseIthinkthisis 

7 tremendously important and I want there to be no doubt in rn> 

6 mind that I’ve told you everything that I know. 

9 MR. SUSANIN: Can I interrupt with a question? 

D BY MR. SUSANIN: 

1 Q Sir, you’ve testified with regard to this last 

2 incident that the President - or that you let a woman into 

3 the Oval Offke on this morning before you went to the 

4 outside post. Was that woman indezd Ms. Minsky? 

5 A Yes. sir. 

Friday, July IT,1998 

Page31 

1 BY MR. PAGE: 

2 Q Canyoutcllus.fmmtbctimctbatyousaw 

3 Ms. Lcwiosky enter tlz mom until approximately &c time you 

4 wsntoffsbiftbowmucbtimcbadgoncby? 

5 A I can give you a ~1 approximation. 

6 Q Allright. 

7 A DqxndingontbctimctbcPrcsidcntcamctotk 

8 oval originally. and our &Sting, so yuu undastand, is that 

9 ifhtgotthac15minutcrbcforrththalfbouritsclf.we 

0 wouldba~r:brml5miouoerandanagentwouldbavc 

1 ~youonthcbalfhoursothatwcdon’tgatbcmtations 

2 askew. 

3 somybcstKcolkctionistbatIwason~tbc 

4 fint post, maybe 20 minutes. but I don’t bavc an exact 

5 ruolkction of tbat. That’s an approximation. 

6 ‘Ibcnitwouldbanoccurrcdootkbalfbourort& 

7 &nIr,wbichcveritwaddbavc~andthenit’svayckdr, 

8 bcuruscIwouldhavt-itwaslcrs~a-minuceandahalf 

9 tohavcachrallygoncdownthcscaimaytograbajackctto 

0 colatbackupandtbentotakethtpostandtbcntolookinto 

1 tk oval. 

2 SoIwouldba~baenonthatpostnomotetban 25 

3 minutes at max. so you’re looking at my total time being45 

4 minutes total. With ttyst approximations. 

5 Q SotosummamC approximakJy 45 minutes, the 

Page 3‘ 

1 Prcsidcnt was with Ms. Lcwinsky, in your estimation. 

2 A Well,sir,I’mnotawarcofanyotJxzpaopkthat 

3 nratinthcoval. Istiapossibility4 Q Excuse me. Oval Office, cm? 

5 A Yes. Ionly-wcll,oncctbcyentaultkstudy 

6 rum. which is private - wtrn I say study, tkzc is also in 

7 that BlcB the&s a dining facility in tln~ tbae’s 

B dif’f~tmomswitbinascparatevaysmallsuitc,buttk 

9 8gaUs8re-anybodyyout8lktointhisgraodjury 

3 typically arc going to say the study bccausc that’s bow it’s 

I dcnotcdtous.butinfacttbzarcotbermomsintherc. 

2 SoIdonotknowtbattbcPreai&ntactuaUymnt 

3 intobisprivatcstudy. HcvnStbmugbtbcdoorintotbat 

4 mrb8u8uk TkGdwwascbt&alXlfmul&EcIdonot 

5 koowMyttlioglkrtkrthlotImt. 

6 MlLPAGE: Crmyoumarkoatbis~RF-1,yax 

7 positionatI)lwfmycusawtbcPrcsi&tandMs.Lcwinsky 

Btogcthrr? 

2 hS.WIRTK And,fortbcrcuad,you’rcusinga 

3 blue pen now. 

1 THEwITNEss: Yes. 

2 BY hiR. PAGE: 

3 Q You’re holding a blue pai, you’lt marking in bhr, 

4 lmrmt? 

5 A l%att; enact. 4 

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1 Q And you’ve just underlined the position E-5, 1 with, which is a solid door, so we would open it, we would 

2cxmxt? 2 look inside, and tkn we would notmally leave that door 0~ 

3 A That’s C0f’I.d. 3 sothatwhenhecomsinthathecaneitherleaveitopenor 

4 Q AndyOUkpUtthgadOt- 4 close it behind him. 

5 A That represents me. That would have been my view 5 Q Didyoudothat? 

6 into tk oval through the window and the doorway. 6 A Idid. 

7 Q Andwouldyoudrawalinefromthedotandjust 7 Q WhenyoulookedintheOvalOfficeonthisday 

8 theninitialattheendofthelineRF7 8 urc’ve been talking about, was it empty? 

9 Now, this is your viewpoint from E-5 into the 9 AYes. 

0 ovaIoffi&onthis&ywe’vebeendiscussingwhereyousu 10 Q NootherpersonwasintheOvalOffkeonthisday 

I Ms. Iminsky and the President, correct? 11 thatwe’vebecntalkirrPaboutwhenyouloolredintosee. 

2 A b-reCt. 12 A Yes, that’s ixxrcct. 

3 Q. How near, approximately, to them are you when you 13 Q And no one entered before the President entered 

4 = th3.71 together? 14 corrtct? ,,., 

i 

5 A Twenty feet, twenty-five feet. 15 A -hat'scomet. 

6 Q Twenty to twenty-five feet? 16 Q AndnooneotherthanMs.hwins&enteredafter 

7 A Approximately from here to that doorway, sir. 17 sheentntd,lzormct? 

8 Q Fromyourseatinthisgrandjuryroomtothedoor, 18 A NotwhileIwasonthatpost,sir 

9 the exit, correct? 19 BYMR.BITIMAN: 

10 A Yes, Sir. ‘Ihat’s cm’rect. 20 Q Whenyounoticedherpassthefvsttitne- 

‘1 Q Howlongdoyouseethemtogetherbeforetheyleave 21 A Y-sir. 

2 the Oval Offke or the oval, in your words, and depart the 22 Q Wasthataninternpassorafull-timepass? 

3 oval office? 23 A I’ve thought and thought about that, trying to 

4 A As I looked into the oval to find the presence of 24 recall, and I do not recall. But it’s not - in our normal 

5 theRaident,tomakesurewheretheactualbodyislomted 25 tx~urslc of busineq it would not be masonable for us to have 

Page 34 Page 3c 

1 itwasatthatsametimet.hatIsawthemproceedingintothat 1 ever allowed her into that area without one of the two, but I 

2 studya.rea,sothesameti.me. AsIlooked,Isawthem 2 do not recall specifically which pass she had on. 

3 proceeding into that area. 3 Q The second occasion that you’re now &scribing, was 

4 Q Can you describe what they wets doing? 4 there a uniformed division officer also in your proximity 

5 A I don’t recall any physical contact at all. 5 whenMs.Lewidcyentemd? 

6 Q Well, I mean, were they walking together? 6 A Proximity, sir? ?he normal court is that the 

7 A Yes. Together being in close proximity, yes, sir. 7 uniformed division officer will hold the agent post 0 

8 As to who closed t.hc door, I don’t know. 8 outsidetheovalonlyduringthosetimesthatthePtesident 

9 Q Didtheyappeartobetalkingtoeachother? 9 isnotinproximity. Inotbcrwords,inthatarea Tkyare 

0 A Not that I recall specificalty. 10 delegated to different postings and move from that area. 

1 Q Before you saw the President and Ms. Lewinsky 11 lhatagentoroffi~gencmllymovestoapost~~ 

2 t~etherintheOvalOffice,wasthePresidentintheOval 12 ei a post which is down a hallway betwan the 

3 offlcealone? 13 oval and the Vice President’s office, well down a hallway 

4 A Tothehestofmyknowledge,thePresidentwasi.n 14 fromthcoval. 

5 theovalalone. 15 Q That specific incident. 

6 Q Cantherebeanytcasoninfactthatwouldsuggest 16 A Right. 

7 that be was with anybody else other than Ms. hvinsky? 17 Q The President came outside and told you he was 

8 In other words, did you hear any radio ttafftc, did 18 expecting somone or some people. 

9 you have any personal observations yourself? 19 A Yes, sir. 

0 Did anybody else tell you he’s in there with 20 Q Was there a uniformed division person there as far 

1 someone or is expecting someone else? 21 asyoucanrecalI? 

2 A Iwasthefirstpersontothatpostpriortothe 22 A NotthatImcall. 

3 arrival of the President and in doing so, every agent will 23 Q Do you know OfEeer Lou Fox? 

4 open the Oval Offke door. 24 A Yes,sir. 

5 It’sunusualtocomehbughthatdaortobegin 25 Q Washetke? 

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1 A NotthatIrazalI. 

2 Q And so no one was thcrr that you rccall. 

3 A No, sir. Tk reasonable course would k tkrc 

4 would have ken an officer tbuc. Oftcntimcs. tky will move 

5 akad of his arrival which is tk appropriate thing to do. 

6 Samstandthacas)ongastbeycanandaskani~,but 

7 quk honestly, baause k was not at tkl()my wsonabk 

8 expectation would bavt b&a that k would have b&n at tk 

9 @But&I RCA sp&fically a person, no, sir. I 

0 don’t. 

1 Q ThcPrcsidcnttoldyctukwasapectingsomeoneor 

2 somcpa~pk. WhcnMs.Lcwinskyanived.didskappcartok 

3 UC pason that k was apsting? 

4 A Yes. No one else during my pa%d on that post 

5 anivcd. Sk was tk fnn His a&now-t of kr to me 

6 would have suggested to pit xasonablythatthatwaswbok 

7 wasexpcctillg. 

8 Q AndwhenyouuryskwasintbtOvalOffrawith 

9 tk Prcsidcnt for 45 minutes. it was at least 45 minutes in 

0 that sk entcxed, you VEX tbec outside tk Oval Office and 

1 then you switched posts to outsick saw tlxm in tk Oval 

2 Offlcc and thtn saw tkm move to tk study area or into tk 

3 study, actually. I guess. right? 

.4 A WclL not to mince words. but my positive testimony 

:5 is,sir,tbatIdidlaherintothcOvalOfficcwhcnIcamc 

I change. But for this circumstance, we did not find there to 

2 be a protective problem with where he was located. 

Page 38 

1 to tk*st. 

2 Afterthafifsonxbodyfamcin~tktime 

3 that I was gone. did not come tkz betwu.n tk time I was 

4 gone. I have no rczokction or knowkxige of. I can only 

5 testify that I did let kr in at that time and that wkn I 

6 did look &rough tk window and a door that I did see 

7 h&x Lcwinsky and tk Rsidcnt procad into what we commonly 

8 refer to as tk private study axa which is adjacent to or - 

9 we call it behind tk ovaL but. in fact, off to tk side of 

0 tbeoval,which&bisprivatcstuclyarcaandtbczcisalsoa 

1 Privatcdiningroom~thcRsidcntisinthclrcandotha 

2 rooms.buttkfactoftkmattuisitwasvaybrkf. 

3 Isawtkzncnprtkdoorway.tbedoorclosalaad 

4 tkt’stklastIsawtbbn. Soasfaraskwmuchtimcwas 

5 tkreanybodyclseintbxdmingthatpaiodoftime. 

6 tb&snowayIcananswu. I don’t know. 

7 Q Did you note to anyone &at tk Prcsidcnt had moved 

8 fmmtkovaltotkstudy? 

9 A No, sir. We would not typically - that is not - 

10 WC would not typically do that. He is within he confines of 

!I tk oval. Tk only time that we would mahn that is during 

!2 a normal day when k would have gusts in. say, for a private 

!3 lunckon of one natux or anotkr or tk Vice President and 

!4 k had lunch in his particular private dining room, we would 

!5 denote that because poshgs dming those activities wduld 

3 Q And they where in behind that closed door for the 30 

4 minutes that you wutz on that post. 

5 A To the best of my knowiedge, that’s comxt. 

6 Q Had tbey left that area, you would likly have been 

7 notified. Isn’t that correct? 

8 A Would I have been notified if -- if the President 

9 had left the confines of that oval suite, yes, we would know. 

0 Q And you wue not so notified. Is that correct? 

1 A ‘Ihat’samxt. 

2 MR. BITIMAN: I’m sorry, Ed. 

3 BY MR PAGE: 

4 Q Witbthispea,Mr.Fequson,canyoumarkthe 

5 study,tbtarcawkreyousawtheksi&ntandMonica 

6 LewinskygotowhentheylefttheGvalOfke? 

7 A Yqsir. 

8 Q Markitwithadotandthendrawalineoffofit, 

9 please, and initial it. 

10 SOthCZytXltCRdthiSi3X3here,COllTXt? 

!I A -hat’s concct. 

I2 Q And that’s known as the study? 

13 A Agmtswmmonlyrefertothat,andallofthe 

:4 unifoxmed division personnel th$ you will speak with, that 

:5 willbe commonly refd to as the prcsidcntial study. 

Page! 4\. 

1 Q Now. under your initials that, can you put in 

2 Pa-tk=ssardy7 

3 Andun&tkfnstlocationonRF-1 IaskaIyouto 

4 markyourpositionwkoyoulookedintkOvalOffice? 

5 A Yes. sir. 

6 Q CanyouputunderRFinp~positionoutsideof 

7 Oval Offi? Tbat’s accurate cmrat7 

8 A Itis. 

9 BY Ms. WlRTI% 

0 Q ~.Iaskyouacoupkofq~tionswknyou’re 

1 donewiththt7 

2 I’m ping to switch topics just for a moma& 

3 Areyouawareofanyotlx7SecrdSaviccanpluyuxwkhave 

4 soenMonica~intkareaoftkOvaloffii? 

5 A Nar 

6 Q Tkdaythatyou’rctefmiugtotkscccdtimc 

7 that you saw Mmica Lewillsky? 

8 A Ycs.tua’am. 

9 Q DoywknowwkthatkRcsidcnt’ss~~ 

10 workingtktday7 

!I A Thy~~~nottlrz Iftbywatworlc@or~~& 

!2 Idomtkmw. 

!3 Q Doyuukwwwkreplaccdyouattk~that I 

!4 day7 I 

15 A No.rua’am IQn’t. I 

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1 BY MR. PAGE: 

2 Q From yt~~ vantage point and know* that day that 

3 w&c ban dkussing, w8s tk door at tbc 1 zO0 position 

4 closedorwasitopul? 

5 A Closaksir. 

6 Q Closai? 

7 A Yes. sir. It was closal. 

8 Q Didyouevas&BettyCurricorNancyHanr&h 

9 thfJtday7 

1 0 A No, sir. 

1 1 d InyourtimcontkPPD,eitkrbeforetkcvau 

1 2 wc’vtbcentalkingaboutarafter.didyoucvabtarfrommy 

1 3 sourcc,Mypu=h~y~ about h4s. Lcwin&y a&or tk 

1 4 Prcsidmt? 

1 5 A No, sir. 

1 6 Q None h fellow PPD manbu or unifamd divisioo? 

1 7 A Ibavealm@ranswcz,ifItnay. ThcanswuisI 8 MR. PAGE: Han8 on a second. 

1 9 MR. WISENBERG: Go akad. 

2 0 THE WTINESS: Tk prcsidcntial prothve dcsail 

2 1 understands tk importance of confidentiality io rc8ards to 

2 2 whattbcPresidentdocsordoesnot&. 

2 3 I can t&l you without a doubt in my mind that any 

2 4 conversations in regard to that Fit Family that will 

2 5 jap3rdk how close a proximity wc can work jcopardiz&tbc 

PagtN Friday, July 17, 1998 

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seangcpasmas~ewfsomcthingoutoftbc 

onihaty. We would. But in m to Mrs. -sky. there 

wasnothingssfarasIwascMccsncdtbatwasoutoftbc 

Ordinary. 

I didn’t m 4 ha spchfically until I 

~lizeathatthcpcrsontbstIsawon~ionwasinfact 

tbcladythstI’dbadthosetwoencaunta-swith. 

BY MR. PAGE: 

Q Speaking about t&vision. = that monitors that 

would have pi&xl this up thin day? Meaning video monitors. 

closed circuit T.V, things like that? 

A. IwoukirspcctfullyIikctotakeamommtin 

X@?Udsto-Imcan,ccrtainfyIhaWto m you. sir, 

andIwantyoslrohrowthatIwilldothatforthrightly, 

butIwouldliLcthcoppanunityto~tomy~lcounscl 

for just a maMltinKgardstothntissuc. 

Q All+ Beforewegothat.hmttmpomrily 

passthcqucstiaarrndarkyou,witboutQingtbtmathinywr 

hi& you’re saying at a minimum*Presidaltwaswitb 

Ms. WLy for approximately 45 minutes during your - from 

thcfirsttimywrawhauntilyoumadeashiftchangcoff 

of E-5. 

A Yes. sir. Again. it was approximately berwoea 10 

and 15 minutes while on -and artsinly 30 minutes during 

d=Ukting. 

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way that the Secret Setvice will do their job. 

Obviously a court has ruled otherwise, but I can 

tell y?#forthrightly and having been there that this will 

affect -- and every agent knows that this will affect the way 

that we can protect the President of the United States. 

MR. PAGE: I think we’re going to, Mr. Ferguson, 

excuse you right now and leave that question about w 

video, for another day. 

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We have sworn an oath to do that. We have done the 

bestthatwecanandwerealizeafterhearingthingssuchas 

the Gennifer Flowers situation, after hearing about the Paula 

Jones information, that we are counselled what occurs there 

stays there. 

We know that to protect them in their private lives 

itisofgreatvalue. Thereasonbeingisthatifwelose 

the confidence of the presidency, we lose the proximity and 

whenwelostthatproximity,wefaelthathislifeisin 

greater jeopardy and those of the agents who protect him. 

So that’s the long answer and I appreciate you 

hearingme. Buttheshortanswer is, sir, that we will not 

speak among ourselves, to the best of my knowledge, about 

anything like that. 

If them is something irregular or something we 

feel that is of a protective nature - and that’s not only 

physical, that’s from what we call protective intelligence, 

if we hear or we have any information at all based on - 

we call it gut, but that’s on your experience, that we 

will do something to let others in that detail know. A 

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THE WITNESS: May I do this? May I provide that 

question to our counsel so that I can give you an accurate - 

MR. WISENBERG: You’re free to talk, of courm, to 

your counsel about anything that you want. We very well 

might have to see you again at a future time, but for today, 

thisisallthetimethatwehave. 

THE WFIhJESS: Understandable. 

MR. WISENBERG: Thank you very much. 

May the witness be excused? 

THE FOREPERSON: Yes. You are excused, 

Mr.Fcrgusoqsubjecttomcallatalaterdate. 

MR WISENBERG: Thank you. 

THE Wrrl%Ss: Thank you. 

(TbtwitnesswaSCXtl&_) 

(Whereupon, at 3:40 p.m., the taking of testimony 

intheprezncc of a full quorum of the Grand Jury was 

concluded.) 

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1103 

In re: Grand Jury Proceedings Multi-PageM July 23, 199t 

in the presence of a full quorum of Grand ;zry 91-5. 

impaneled on December 5, 1997 commencinq a: ::53 p.m. bet--se: 

ECuAm PAGE 

Associate Independent Counsel 

*n4oT"Y SUSANIN 

Associate Independent Counsel 

JACKIE n. aENNET1, JR. 

Deputy Associate Independent Counse: 

Office of Independent Counsel 

1001 Pennsylvania Avenue, W.W. 

suite 490 YoreI 

WashinqWm. D.C. 20004 

CONTENTS 

Paqe ; 

i4ITHES.5 : FZE ‘

Robert Charles erquson 3 

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PROCEEDINGS 

Whereupon, 

ROBERT CHARLES FERGUSON 

was recalled as a witness and, having been previously duly 

sworn by the Foreperson of the Grand Jury, was examined 

further and testified as follows: 

THE FOREPERSON: Before you sit down. sir. you were 

sworn in to a grand jc? 

THE WITNESS: Yes, ma’am. 

THE FOREPERSON: About this particular matter that 

we’re hearing today? 

THE WTTNESS: Yes, ma’am, I have been. 

THE FOREPERSON: Okay. So you understand that you 

are still under oath? 

THE WITNESS: I do. 

THE FOREPERSON: Okay. Please be seated_ 

h4R. PAGE: And again, let the record reflect that 

we have a quorum and that there are no unauthorized 

individuals in this grand jury room. 

THE FOREPERSON: That is correct. 

MR. PAGE: Thank you. 

EXAMINATION 

BY MR. PAGE: 

Q Would you tell us your full name, please? 

A Yes. Robert Charles Ferguson. 

Page 4 

1 Q Mr. Ferguson, I spent a good amount of time last 

2 Friday in this very room before a different grand jury 

3 advising you of your rights and responsibilities, correct? 

4 A Yes. sir, you did. 

5 Q Do you have any questions about those in today’s 

6 session? 

7 A No, sir, Mr. Page. I don’t. 

8 Q I’m not going to go over them with you, with your 

9 permission, because you understood them at the time, you have 

0 no questions today, and you have served in the Federal 

1 service for a number of years, correct? 

12 A I have, yes. sir. 

13 Q So you understand your obligations and 

14 responsibilities? 

I5 A Yes, sir. Yes, sir. 

16 Q Would you please speak up -- 

17 A Certainly. 

18 Q -- SO that the woman in the far left of this room 

19 could hear you, and have tbe benefit of your testimony. 

!O Last Friday, we visited - I should say I asked you 

!l about - several topics, correct? 

!2 A Yes, sir, you did. 

!3 Q I want to first show yb;’ what I have mark&l today 

!4 as Grand Jury Exhibit RF-l. 

!5 A Yes. 

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Page 5 

1 (Grand Jury Exhibit No. RF-1 

2 was marked for identification.) 

3 BY MR. PXGE: 

4 Q And I would ask you to study that, please. for a 

5 moment, so that I can ask you some questions about it. 

6 A (Examining) I’m quite familiar with it, sir. 

7 Q You’ve worked in there. correct? 

8 A Yes. sir. I ha1.e. 

9 Q And that is “there,” meaning the White House? 

0 A Yes. sir. the \Vest Wing of the White House; yes. 

1 sir. 

2 Q I’m SOT. That’s the West Wing of the White 

3 House? 

4 A Yes. sir. 

5 Q Would you hold that up for a moment, just to let 

6 the members of the grand jury know what we’re talking about? 

7 Now, which way is north on RF-l? 

8 A North. through what would be close to where the 

9 destination, your grand jury exhibit would be. That would be 

:O north, from my recollections. 

1 Q Where tbe red sticker is? 

.2 A Yes. sir. 

:3 Q When did you work, approximately, at the White 

4 House? 

5 A For the Presidential Detail? 

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Q Correct. 

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A Late - approximately late ‘94 through ‘96. Well, 

actually, it was ‘97. part of ‘97. 

Q Part of ‘97? 

A Yes. sir. 

Q Late ‘96. part of ‘97? 

A Late ‘95. actually, part of -- ‘95 through ‘97, 

just about that entire. p&iod of time. That was also with a 

stint through the transportation section, but which would 

have taken me from t& White House, but we varied daily. 

Q And you said this was as a member of the 

Presidential Detail? 

A That’s correcf yes, sir. 

Q Tellthememlxrsoftbegrandjurywhatthe 

Presidential Detail is. 

A The Presidential Protective Division is a detail 

that - within the Secret Service - of generally very senior 

agents who are selected for the President’s Detail. 

When we say President’s Detail that is the group 

of agents of approximately 100 men and women. who provide a 

protective function for the President. Now, this is just 

%=lB. 

Now, there are other Secret Service personnel 

involved in that. which would be our Uniform4 Division, 

others that I’m sure that counsel will get into. 

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But for that purpose, the Presidential Detai! 

protects the President, the First Lady, Chelsea, on a fulltime, 24-hour basis. 

Q E\zn with the White House complex? 

A Yes. sir, that’s correct. 

Q And even within the West Wing of the White House 

complex? 

A Yes, sir, that’s correct. 

Q And so RF-l, would that help you explain the 

positions that you may have taken in serving on this 

protective detail? 

A I think this would illustrate very well some of 

those functions, yes, sir. 

Q That’s what I’d like to start with. 

A Okay. 

Q Last week, you testified, I believe - and correct 

me at any time if I inaccurately summarize your testimony 

-- that on one day you were stationed at w 

A &es, sir. 

Q Okay. Speak up, if you can, please. 

A Yes. 

Q b%en you were atm -- can you tell the members of 

the grand jury where that is located, first of all? 

A Yes, sir. amme 

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He would not normally go into the West Wing complex 

and through the hallways to the Oval, he would go down the 

outside, on the colonnade, as most Presidents have done for 

generations, and proceed into the Oval that way. 

Can you write with the pen I’m handing you -- 

I have one. 

You have one? 

Yes, sir. 

Okay. - the position w 

Mr. Page, these were approximate locations. ‘Ihey 

don’t give you a static location. So-, for us, normally 

is this. “B.C.,” I would assume, stands for Betty Currie -- 

Q Correct. 

A - which would be her desk, approximately. So 

within that, we try our best not to stand in front of Mrs. 

Currie’s window all the time. 

So generally, _I--- 

- 

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Q All right, now, you’ve marked three additional 

positions, correct? 

A Yes. Yes, sir. 

Q -adI) 

A I) that’s correct. 

Q And these positions that you’ve indicated with your 

pen on RF-l are approximate, correct? 

A They’re approximate, yes, sir. The only other 

position that is not located on this mapping would be one we 

refer to as-or N which is a post from this 

mapping, sir, being in the same coordinates, would be a 

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3- (Interruption to the proceedings.) 

4 BY MR. PAGE: 

5 Q We’ll go back for a few moments. Let me ask you, 

6 on RF-l, the diagram that’s in front of you now, that’s of 

7 the West End, correct? 

8 A Yes, sir. 

9 Q White House complex? 

0 A Yes, sir, the West Wing of the White House, yes, 

1 sir. 

2 Q You’ve just marked hvo “Ws” on the outside of the 

3 oval Office, correct? 

4 A Yes, sir. 

5 Q And they indicate the two windows that separate the 

6 interior of the Oval Office from the colonnade on the 

7 outside? 

8 A YeS, Sir. 

.9 Q You also marked “D” for door; correct? 

!O A Yes, sir. 

!1 Q And there’s one door from the Oval Office outside 

!2 to the colonnade, on that side? 

!3 A ‘Ihat’s CmeCt. 

!4 Q Now, earlier, we were talking about the position 

!S that vou took when YOU nersonallv .guarded the President from 

Page 10 

I that area, correct? 

2 A Yes, sir, that’s correct. 

3 Q And you marked w? 

4 A ‘e yes, sir. 

5 Q I want to ask you if there are other positions from 

6 which you guard the President, or guarded the President when 

7 you served, that are near * 

8 A Yes, sir. 

9 Q And I don’t mean as you flex back and forth. I’m 

,O talking about specific positions, like I’m sorry, a 

11 Am 

,2 Q-L 

A m Yes, sir. Those are the primary ones, 

::-ande 

,5 Those indicate locations throughout the West Wing 

16 that the agents would take up those positions _ 

i7 around the President, so that 

18 we can monitor all of the comings and goings of people withir 

19 the West Wing for that period of time while the President is 

!O within the West Wing, particularly within the Oval Office. 

!l Q All right. Would you go ahead and mark them, 

!2 please? 

!3 A Yes, sir. . 

: 

14 Q And then I’ll ask you questions about them? 

15 A Okay. 

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that posting. 

In other words, when we bring the President over to 

the Oval, one of the Presidential Protective Detail agents 

will assume that post from our Uniformed Division, who will 

then leave that post for another assignment. 

Q Can you give us the general area where ms? 

A Yes, sir. From the Oval, it’s -- there’s a walkway 

down to the south roadway, so i/_-p 

4 

S The Rose Garden, obviously, coming off, they’ll go 

Page 12 

I down. There’s a -- may I draw on it? 

2 Q You may. 

8 Q Are there any other positions, besides those that 

9 you’ve now indicated, on RF-l? 

0 A No, sir. 1’11 just markmver in here. No, 

I sir, that’s all. 

2 Q 

3 A 

4 Q 

5 A 

6 Q 

7 A 

8 Q 

So how many, total,, do we have? 

Four. (v-and _ Five. 

Well, five. But five is -- .* 

Four that you can see here clearly. 

Four in close proximity -- 

Yes, sir. 

0 A-. 

1 Q What about above or below, on different floors? 

,2 Any duty stations there? 

13 A Not normal pro&t& functions for the detail: 

:&&here could be agents on -- well, obviously, below the Oval, 

‘5 just down from that. 

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Pag 13 

It’s called -which stands forwhich is the Secret Smite command post 

which also doubles as many functions for us. But that’s 

where we have a ready supply of other personnel that are 

rotating through, and also in response mode, of whatever we 

need to do. 

Above that. in the West Wing, there are other 

offices. to include the First Lady’s office which, obviously. 

if she is in there as well. there would be agents on those 

postings. as well. 

Q Now. last week. wben you were here testifying, you 

mentioned two incidents that you recall, where you saw Monica 

Lewinsky, correct? 

A Yes, sir, I did. 

Q I want to visit wilh you briefly about those two, 

again. to give the members of the. grand jury here an OV~~TGZV 

of what you saw and testified about. 

A Yes, sir. 

Q Let’s talk about the fust one. Can you summarize 

what you saw on that occasion? 

A Yes. sir. The information that I can provide for 

you is -- is the best of my rtzollection. I have no hard 

facts, nor do I have any notations or anything other than the 

general memory of a person in that situation. 

So I can tell you this. My fust -- first 

Page 14 

I encounter with a woman, later that I believed to be Monica 

2 Lewinsky, was in the winter, I want -- the winter of ‘96. 

3 And it was a normal business day. 

4 And thz reason that I know it was a normal, it was 

5 Monday through Friday -- which day of the week, I don’t 

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That suite of off&s does have a do&that leads 

directly into.the Oval Office. Therefore, the Secret Service 

would hold a post just outside that door, for the comings and 

goings. ow 

In *West Wing $f the White House, after the 

years that we have been there, most of the staff know us and 

we know, at least by face, if for no other reason, most of 

theil%taff: <II 

The reason that was of note to me is because the 

woman I believe to Mrs. Lewinsky approached that. And I 

don’t know specifically that I stopped her, but we would 

routinely stop, say “Hello,” something, in order to slow 

them, to look at a pass that they would be wearing. 

I do recall allowing her to continue into Betty 

Currie’s office, which would indicate to me that the pass was 

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offices. And. once inside thex, I have no idea who she saw 

or what she did. 

Q I want to ask you some questions about the time 

frame. ‘i, _ ,&:, 

A Yes. sir.‘+. 

Q You earlier characterized this with. I believe. 

some hesitation -- correct me if I’m accurate. or inaccurate 

-- that this. you believed. was in the winter of 1996? 

A It is purely speculation on my part. I do recall 

it being the wine. @bviously,-bp,,* testimony I’ll 

probably provide you later. I recall it being cold. I recall 

it being a regular workday. 

Because of that period of time. sir. it’s very 

-- I’m giving you my best guess, in regards to the time 

frame. 

Q I’m more intexsted in the accuracy of the year - 

-- and hear me out - rather than, I should say, the time of 

Year. 

A Okay. 

Q I represent to you that Monica Lewinslcy was working 

from in or about July of 1995 through in or about April of 

1996, at the White House. tp-’ 

She first began, I represent to you, as an intern. 

in an unpaid status. And then, in or about Novrznber. 

December changed from a paid employee - I’m sorry -- changed 

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to a paid employee in another office within the East Wing. 

If those representations are accurate, and I don’t 

say that they are - I don’t say that they’re not -- I want 

you to think about whether this was the winter of ‘95, right 

after the Government shutdown that you may recollect or, as 

you’ve testified, the winter of ‘96. 

Because 1’11 further represent to you that, in 

April of 1996, Monica Lewinsky was transferred to the 

Department of Defense and began working at the Pentagon in 

Virginia. ‘* 

Knowing that, and knowing those representations, 

can you tell us if that helps with yoy in accurately telling 

us about the year you think you saw w things? 

A Yes, sir. I wasn’t aware of any of that 

information at all, Mr. Page. But, quite honestly, I’m 

saying ‘96 as my best guess. Could it have been ‘95? l%e 

answer is also yes. 

Q W&l, are you at the White House at the time? 

A At the winter of - yes, sir, at the winter of ‘95, 

yes, sir. 

Q The winter of ‘95. So that is important, 

corTect -- 

A 1 was there. Yes, sir. 

Q -- in making an assessment. You’re there. 
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Q And, if she is at the Pentagon from April of 1996 

onward, she wouldn’t have a White House pzs. 

A Well, sir, let me say this, Mr. Page. I don’t 

recall a m’hite House pass, beinga perm%ienr pass. She may 

have, in fat& dad an intern pass. 

‘But ‘as I indicated to you, I think, my testimony 

last week is that I don’t recall the pass. But I know that, 

for me to have allowed her into that area, would have been an 

appropriate pass, be that an intern or bet a permanent staff. 

But I don’t recall, Mr. Page, right offhand, which pass that 

would have been. 

I appreciate the information you provided but, 

quite honestly, it wouldn’t change my best guesstimate. But 

I really don’t recall exactly. I know it was winter, and I 

can recall those kind of factual information, but as far as 

the period of time, I cannot, sir. 

Q All tight. Thank you. You don’t have much other 

information about that day we’ve been talking about, whether 

it’s the winter of ‘95 or ‘96, other than what you’ve told 

the grand jury today? 

A That’s correct, I don’t. From what you and I -- I 

mean, we talked about in the previous one. the information 

was that I don’t recall who would have taken my post or any 

of that. I have no other recollection of who I believe to be 

Monica Iewinsky after she went into that suite. 

Page 18 

1 Q So, to summarize, you’re on duty; you sec. Lewinsky; 

2 she goes into that outer office; you don’t see her come out? 

3 A That’s correct. 

4 Q Now, you had another day that you saw Ms. Lewinsky, 

5 correct? 

6 A Yes, sir. 

7 Q And I want to ask YOU some questions about that day 

8 now. 

9 A Yes, sir. 

0 Q Areyouatmonthisday? 

1 A Yes, sir. 

2 Q And ms a position in the PPD that you have 

3 indicated on RF-I, that is right outside the Oval Office; 

4 correct? 

5 A On the -- well, to begin that process, sir, when I 

6 first, obviously, observed her -- oh, well, to answer your 

7 question, yes, sir. That’s much later. But, yes, sir, 

8 that’s correct. 

9 Q So let’s back up. Because before that, you were 

.o actually ate 

:1 A I was. Yes, sir. 

12 Q Let’s start there, and summarize, for the members 

13 of the grand jury, what took place ate ’ 

!4 A At that particular day, I know it was Saturday, I 

!5 can tell you, and it was only -- I believe I told Mr. Page 

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and tbr -grand jury previously, I recall it only being a few 

shoti weeks between the two. because I had never seen Mrs. 

Lewir&y before. 

And a few - it wasn’t -- I would say within a few 

weeks. it was on a Saturday, and we came - being, “we” being 

the F+esident and the shift of agents working that day 

- came from the mansion, down the colonnade and into the 

West Wing. through the door we normally don’t go through. 

And my assumption would be that we went that way 

because there’s nobody working. I mean, the President very 

rarely comes inside the Weat Wing to entez the Oval from that 

direction. 

That particular day, I was leading the President 

well up the colonnade, and I actually go through a couple of 

sets of doors, and make sure that the Oval is prepared and 

the doors am open. before the President, to check if to 

make sure that everything looks appropriate, and we step to 

the side. and the President enters. 

Well. as the Resident enters - I have driven the 

President. through our transportation section, for almost tu’o 

years. so the President knows some of the agents very well. 

And tk comment he made to me was -- and I don’t know if it’s 

appropriate - he made a comment to me. 

He says something like, “Bob,” or “Fug,” did you 

get a haircut?’ And I says, “No, sir.” And the Resident 

Page 20 

1 goes. “Oh,” meaning -- I think he’s talking about the spot 

2 getting larger all the time. 

3 But, at any rate, he made the comment. And he went 

4 into the Oval, and he must have closed the door. I didn’t. 

5 A short time thereafter, the President opens the 

6 door and says, “I’m expecting” -- to the best of my 

7 recollection - “I’m expecting staffers” -- “some staffers.” 

B “Yes, sir.” And “Let me” -- something to the effect of, “Let 

3 me know when they’re w Which is unusual for me. 

3 Now, this may not be unusual for others. It was 

1 unusual for me. And I said, ‘Yes, sir.” I found nothing out 

2 of tke ordinary. It just -- I hadn’t had that occur with 

3 this President. 

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So I was there for, I don’t think it was a long 

period. a short period of time. I would have oaly been on 

that post. at the maximum, 30 minutes. 

And that’s when a woman I believe to be Monica 

Lewinsky, who I recall, having never seen before, from a 

Couple of weeks, or maybe even three weeks earlier, going 

into tk west lobby. She came to the door and said, “The 

President needs me.” 

So I knocked on the Oval Office door, at_ 

opened the door. l%e President acknowledged - I don’t 

recall him saying anything, but I recall some acknowle&ment 

that would have ma& me understand that that was the pason 

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he was there to see. 

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She went into the fial Off&, and then I closed 

the door. And that’s the last that I had seen her during 

that period of time. 

Q Now, that was from the vantage point of m 

correct? 

A Yes, sir. That’s an interior post at the Oval 

Office, on the inside of the West Wing. 

Q At the, some would call 11 O’clock position? 

A Yes, sir. 

Q If the Oval Office is a clock? 

A Yes, sir. North being, obviously 12:00, that would 

have been that position, yes, sir. 

Q Did you maintain that position? 

A Yes, sir. I maintained that until, we call it a 

push but, in fact, it’s when you’re relieved by another agent 

in your working shift of, generally, Jive to seven men and 

women. So I was relieved from that position to go to my next 

position. 

Again, the reason I recall it being a Saturday is 

that normally we would go from the _ 

L w tom which is just from here to the doorway, 20 

3 feet, 30 feet, as another observation post that would watch 

4 the comings and goings from -- into, excuse me -- into Mrs. 

5 Currie’s office, which would be another entrance into the 

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Oval, which we would want to have view of. 

Well, we were not holdinfiost. and the reason 

we did not is because Mrs. Currie’s office and all the others 

were closed that day, and would have been locked. So that 

-- and from the_ is a very good vantage point to see all 

the wav down the hailwav. So there was no reason for us to 

hold @ 

. 

Our next post normally, in a normal course of 

business, if I would have left, would have been to go outside 

the complex to the Rose Garden, and go to what is called m, 

or w. 

That partidalar day, we did not hold thee post. 

And postings change, depending on what’s happening. We 

-- that particular day, we did not, on that particular shift, 

we did not hold the -post. There could be a myriad of 

reasons we didn’t, but we did not. 

So I went right from our-position to what is 

commonly referred to as- or m which is the post just 

outside the Oval. 

I recall it&zing a winter day because, when I left 

the * post, which was hurriedly coming over from the 

mansion, I did not bring my overcoat from down in -- which 

was located in m_ which is our operat&ns center. 

As I left )cI proceeded toward theeost, 

stopping, going down the stairs for a moment to grab an 

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overcoat, and then huniedly going back up the stairs and 

outside to the colonnade, where I relieved another agent who 

was already standing out there, and then he went to, would 

have been m, would have been to go back down tom. 

So that’s -- so that states, sir, my movements. 

Q All right. Thank you. Now, you’re at 1)1 And 

tell the members of the grand jury what you see from that 

vantage point. 

A Because I had gone to m, that’s probably another 

45 seconds longer than I would have normally anticipated, I 

didn’t -- and the agent on post is cold, and wants to come 

off. So there was no communication, to the best of my 

recollection. 

So I stepped further toward the Oval on the 

colonnade, and looked through the window door, which are 

glass, glass framings, into the -- yes, sir? 

Q Excuse me. Both windows that you’ve marked with a 

“W” are glass? 

A Yes, sir. 

Q Correct? Not tinted? 

A They are not tinted, to the best of my knowledge. 

Q You can see through, into the Oval Office? 

A Yes, sir. 

Q Correct? 

A Yes, sir. 

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And the door, is that a solid door or a glass door? 

It’s glass paned. 

Glass paned? 

Yes, sir. 

And you can see through that, as well, correct? 

Yes, sir, that’s correct. 

No curtains blocking your line of vision? 

No, sir, not to obstruct your view. There are 

curtains, but they don’t obstruct the views. They’re - I’ve 

never seen them closed. 

Q Go ahead. l-hank you. 

A I stepped closer to the Oval, to look through the 

window quickly, to make sure that the President, in fact, was 

in the Oval, that there hadn’t been a movement, or I didn’t 

miss a signal on the radio of a movement of the President. 

AsIwas-asIlookedt.hroughthemtofmdthe 

President, I saw the President and, again, who I believe to 

be Monica L.ewinsky going through, into what most of us refe 

to as the study, in fact, into a private quarters helonging 

to the President, which -- which houses his private dining 

room, there’s a study, and other small rooms, into that area. 

As they -- as I saw them, I saw them pr+eed into 

the room, and the door closed. 

Q All right. I want to ask you some additional 

questions about what you’ve just testified about. 

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1 A Yes, sir. 

2 Q When you say “study,” I want you to look at RF3 1 -- 

4 A Yes, sir. 

5 Q -- and tell us what you mean by study. Because, 

6 to that side of the Oval Office, is it not true that’ there 

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arc a number of rooms? 

A Yes, sir. ‘Ihe Oval office complex, we’re talking 

about the study, there’s his dining room, that’s the -- and 

only one doorway into that area. 

So what I observed are the two of them actually go 

through that door and then, in fact, the door closed. But 

most of the agents and officers that will testify will say 

that he went into the study. If, in fact, he went into the 

study or not, we don’t know. It’s just that that’s what we 

call the area. 

But he proceeded in -- the President and, I 

believe, Monica Lewinsky, went through that door, and then 

the door closed. 

Q All right. Now, with your pen, can you mark where, 

when you looked through the window and door from #-5, into 

t$e,_pal @Jice, where you saw the P&dent and Monica 

Lewinsky first, before they qtarted on into the study? 

A U’ell, actually, they were approaching it as I 

looked through the window. 

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I had seen her picture on television, and then 

2 that’s when, for me, the two clicked, if you will. That’s 

3 when I recognized her as the woman I believed to have been 

4 with the President during that period of time. 

5 Q And the same woman who had been -- that you had 

6 seen eariier, approximately three weeks, you believe? 

7 A Roughly, yes, sir. 

8 Q Correct. 

9 A Yes, sir, that’s correct. 

0 Q So you see picture on the television? 

1 A Yes, sir. 

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2 Q “Monica Iewinsky” is either underneath it on the 

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Q That’s tine. 

A So they -- 

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Q Indicate tbat area. 

A Yeah. They were approximately in tbis area here, 

proceeding to tbezdoonvay, which is just a few feet away. 

Q All right. You’ve just indicated with two “Xs,” 

coln&? 

A Yes, sir. 

Q And that’s the position that you saw the president 

and Monica Lewinsky at when you first looked through tbe door 

and& the window, from E-S? 

A That’s correct. 

Q And their backs were to you? 

A Yes, sir. 

Q And was this tbe same woman who bad approached you 

before you had changed positions this day? 

A Yes, sir, it is. 

Q And you testified%& you &eved it to be Monica 

Lewinsky? 

3!; A I believe it to be bet-e. yes, sir. 

1 Q Because you bad seen her. a few weeks before, come 

2 to the Oval Office? 

3 A Yes;+. I didn’t -- that was not w,? I came to 

4 know who she was. I still didn’t know who sbe was until this 

5 news came out. in regard to this investigation. 

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TV, or somebody is describing that picture as Monica 

Lewinsky, and you put two and two together? 

A Exactly. That’s the woman I believed I had seen, 

and then three weeks later, in fact, seen her go into the 

-- was in the Oval. 

I know for a fact that that’s, first of all, the 

woman I let into the Oval the second time. And, obviously, 

the one I saw going into the study area when I took the E-5 

post, I believe that to have -- based on the TV, I believe 

that to have been Monica Lewinsky. 

Q Now, can you give the members of the grand jury an 

estimate about how far they were from the door into the study 

when you first saw them together? 

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A Five feet maybe less. 

Q Five feet? 

A Yes, sir. They were proceeding to the door, as I 

looked tbrougb tbe mtbe Oval windows and door. Tbey wem 

proceeding. It’s a direct line of sight. 

Q Is the door into the study - I should say into tbe 

Oval Office complex; is that more accurate? 

A That’s fine. I understand what you’re talking 

about, sir. 

Q Is that door a single door? 

A Yes, sir, it is. 

Q And you know tbat because you’ve been in there 

before? 

A Many, many times. 

Q So you see the president and Monica Lewinsky 

situated as you’ve described. and indicated on RF-I with the 

two “Xs,” tbey both walk into tbe Oval Offtce complex? 

Complex, yes, sir. 

And tbe door closes? 

Yes, sir. 

You have a radio on at tbe time, correct? 

Yes, sir. 

And what is tbe purpose of that radio? 

To provide communication information in regards to 

protective movements throughout the complex, regarding the 

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1 President and the First Family. 1 A That’s correct. 

2 Q Is it routine practice for you to hezr on the radio 2 Q So, but to your recollection, you heard no 

3 a change in the President’s location within the West Wing? 3 transmission, and you would have heard had there been one, 

4 A Within the West Wing, yes, sir, it would be. 4 indicating that the President moved in, for example, to the 

5 Q Give us a representative exchange that you might 5 Roosevelt Room? 

6 hear on the radio. ; f, A Oh, no question. 

7 A If, in fact, he moved from the Oval to the 7 Q Or any other room outside the Oval Office complex? 

8 Roosevelt Room, you would hear the verbiage, “Horsepower ’ 8 A Yes, sir. Normally, I would. 

9 Eagle Roosevelt Room,” which would indicate to us, ; 9 Q Is that accurate? 

0 “Horsepower” be the Secret Service command structure; j10 A Yes, sir, we would have heard the transmission. 

J “Eagle,” which is the Presidential code name, is moving to ’ 1 I And I do not recall, while I was on that post, any 

2 the Roosevelt room. 12 transmission of that nature. 

3 And then we would change our positioning more 13 Q What about the President, now, with a guest? Does 

4 adequately for that area. 14 the Secret Service track the movements of guests that the 

5 Q What about a change from the two “Xs” on RF-l into \ 15 President may be with? 

6 the Oval Off& complex on that diagram? 116 A If they’re with him. 

7 A Not -- sometimes you do, sometimes you do not. The 17 Q All right. So, in other words, really, it’s radio 

8 reason being is that I personally feel that that is, in fact, 118 transmission because of the President -- 

9 part of the Oval. 119 A Yes, sir. 

0 Q Did you make a radio transmission after seeing the 20 Q -- not because of that he has a guest? 

1 President and Monica Lewinsky go into that Oval Office 21 A Absolutely. 

2 complex? 22 Q It happens as a result of the fact that he’s with 

3 A I did not. 23 somebody? 

4 Q Was it appropriate to do so? 24 A Yes, sir. 

5 A I don’t believe so. 25 Q So, in other words, if the President would have 

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1 Q And that’s because that general quadrant of the I moved. you would have heard a radio transmission, correct. 

2 West Wing was still guarded? 2 out of that area? 

3 A Oh yes, sir. 3 A I would have assumed. within that period of time. 

4 Q Is that why you didn’t, or was it a discretionary 4 There could have been traffic, sir, but I don’t recall any 

5 thing for you? 5 radio traffic in that regard. 

6 A To the best of my understanding in how we do the 6 Q Did you make any other observations of Monica 

7 protective function there, I did not feel that it was 7 Lewinsky or the President that day, &at we haven’t discussed 

8 necessary to provide radio traffic. There is no further 8 today? 

9 protective interest, if you will, when he moves from this 9 A No, sir. That’s the last time I’ve ever seen her. 

0 area to that area. It’s covered the same. 10 Q Except for a likeness of her on television? 

1 Q Did you hear any transmission that day, from your I 1 A Yes. sir. 

2 vantage point at m indicating that the President had left 12 Q All right. Now, I represent to you that the 

3 the Oval Office complex, after you saw Monica Lewinsky and 13 publicity surrounding Monica Lewinsky and President Clinton 

4 the Presided enter? 14 began in or about January 18th or 19th of 1998. 

5 A Not during my period on shift. And, once I left 15 And specifically, I represent to you that, on 

6 that position, I would have gone down to w. And I don’t 16 January 21,1998, a Wednesday, the Washington Post, among 

7 recall any traffic indicating that she was them or not. 17 others. published stories about this alleged relationship 

8 What often happens, Mr. Page, is that the President 18 betweenthttwo. 

9 will go from the Oval into the Oval Office complex many 19 Since then, I take it that you have read stories or 

0times.S0- 20 seen press coverage whether it’s TV, radio, or otherwise, 

1 Q In and out? 21 about this matter? 

2 A In and out, yes, sir. So we would be constantly on 22 A Yes. sir. I have. 

3 the radio calling movements that are, in my judgment, 23 Q And. as you’ve done so, you’ve testified earlier 

4 utrnecessary. 24 that it came to you, your understanding, I should say, that 

5 Q Uw? 25 the woman you saw in there that day, as well as three weeks 

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approximately before this, was Monica Lzwinsky? 

A I believe it to be, sir, yes. 

Q Did anything else besides that come to you, that 

helps you recollect what you may have seen or heard during 

your tour of service at the U’bite House? 

A Mr. Page, I have no other information or 

recollection about that lady I believe to be Monica L.ewinsky, 

at all. 

There are, as you know, sir, many, many, many 

interns and staff that come through those areas. Nothing 

significantly ever stuck out in my mind, in regards to her, 

other than the two events that I’ve mentioned to you, sir. 

Q Do you have any recollection as we talk here now, 

without looking at records, of about who was positioned at E8 andlC)after the shift change we’ve discussed? 

A mnormally would be, that would have been the 

Uniformed Division officer that would have been moved fron: 

the Oval door a considerable way down a hallway, the reason 

being is that there is another exit out from this complex 

area, through what we commonly refer to as “the pantry.” 

And they would position themselves for this 

hallway, which - and down to the Vice President, chief of 

staff‘s office, down in this area. But they would have 

positioned themselves further down. 

I do not recall who the Uniformed Division officer 

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I was. I don’t even recall that he was there. Routinely. they 

2 would be, and I have no reason to believe that he wasn’t 

j there. But I don’t recall who it would have been that 

4 particular day. 

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responsibility as a Secret Service agent is to keep secure 

the information that you gather from being stationed at posts 

like E-8. E-6, and E-5? 

A Yes, sir. Absolutely. We do our best to provide 

as much privacy. as welI as security, for that family. 

Q W’hile you were working at th White Houx. as a 

member of the PPD. or in any other capacity, did you ever 

hear any rumors about tbe President and Monica L.&n&y? 

A Only from the - no, sir. I was from - I was gone 

from those arcas to the Special Services Division, (I even 

retired by mosf of this, by the time I heard this. Bur no, 

not in qard to Monica Lzwinsky. Tbe only other nxnors wue 

with other litigants in other cases that I’ve hard fmm 

television. But no recollection of ever a conversah. 

As a marter of facf I think you’re going to f& 

that the service dcesn’t want you to have those kind of 

conversations, because we understand the impact. hat that 

causes. So information that you have in that regard. they 

expect you to keep to yourself. 

Q So other than what you’ve heard on TV, since l-21- 

98, when tbe story broke -- 

A Yes, sir. 

.Q - if that’s accurate. and I say it is, no rumxs 

that you beard about while you were working in any capacity 

at the White House? 

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Q Are &cy on the same radio frequency as -- 

A No. NoQ -- PPD? 

A No, they’re not. 

Q They’re not? 

A No, sir. 

Q Theyhavetheirown? 

A Wefl,withintbe-yes.tbeyhavethzirown. They 

have several. The White House complex has many different 

radio frequencies. 

The Secret Service operate - tke Presidential 

Detail operate off one primary frequqcy. The Fit Lady 

detail would operate off their frequency. Tbe Cbelsea Detail 

would operate off their frequency. 

But. obviously, in tbe command structure. we have 

everybody’s, and we can, from our command structure. we can 

make calls to anybody, and everybody. 

Q Have you told anybody at any time, since making 

these observations, besides this grand jury, the grand jury 

that you spoke with Friday - 

A Yes, sir. 

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Q -- and a couple of agents that came a5 visited 

with you and spoke to you about some of then events 

approximately a month ago? 

A Yes. I - the agency came down, were 3 

professional as they could be, but I gave then absolutely no 

information, ~GXLCX I didn’t feel it proper. 

I think. philosophically, from the !%cz Service 

standpoint, I understand the job to do here. On the other 

hand, philosophically, this is tremendously &tiental, in 

my opinion, on how the Secret Service is goii to do their 

job from here on. And I know -- with that being said, I gave 

them absolutely no information. 

The only other person I’ve ever provickd this 

specific information about was the Departmmr of Justice 

attorney, on tbe night prior to my previous testimony, and 

thereasonbelIlgisthatthereweresomei~inregardto 

privileged information. But on one outside t,Lzt I’ve ever 

told anything like this to. 

Q No friends? 

A No, sir. 

Q No buddies? Nobody knows this -- 

A No, sir. 

Q - but the people I’ve described? 

A Yes, sir. 

Q Is it accurate to say that part of your 

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Q Does President Clinton, in your view, based upon 

the time that you served in the PPD at the White House, did 

he have favorites in the Secret Service -- in other words. 

people that he was more fond of than others -- such as, 

perhaps, yourself? 

A I think the President knows some of the agents who 

have been with him longer. Therefore. he would have greater 

familiarity with them than he would others. 

The average agent doesn’t necessarily, on -- when I 

say “average agent,” being on the Presidential Detail -- they 

don’t normally carry on long conversations with the 

President. Quite honestly, if you’re conversing with the 

President, you’re not doing your job. 

AndEe have a special agent in charge of that 

detail, who that’s his job, is to interact with the 

President. 

the Secret Service enga_ges in as a result of the protective 

sonic: they provide the President. I 

Multi-Page* ’ July 23,1998 

? 

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2 

3 Are there such things called movement logs? 

4 A Yes. 

5 Q And are thmc Uniformed Division ninaaries that 

6 you’re awarc of? 

7 A Not to my knowledge. but that doesn’t mean they 

8 don’t exist, sir. Not to my knowledge. 

9 Let me say this in regard to presidential 

1 10 movements. Anytime he moves from the mansion, off the second 

1 II floor. which is their residence, within that mansion. to 

1 12 another location -- be it anything fr0m the state fl00r, a 

1 13 floor down. on - we normally keep records that would appear 

1 14 on that shift 10g, it’s called a shift log. of that shift. 

I I5 that uas actually working the President for that day. 

1 16 Q Andgivethemembersofthe~ndjurya 

1 17 representative entry, say for the day you walked the 

1 !8 President down from the mansion, doing the advance for the 

1 .9 entry into the Oval Oftice. 

2 !O A Okay. It would reflect something Iike, “Depart 

2 !I mansion at 9:05. arrive Oval at 9:08.” And tbse would be no 

2 !2 other entry until be departed the Oval Oflice. as an example, 

2 !3 at a particular period. 

2 !4 Now. movements outside the complex become much more 

2 !5 detailed. the reason being is we have a greater security 

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We’ve all talked to the President on many, many 

occasions, generally not long, in-depth conversations. It’ll 

be about one thing or another, or about an activity, or a 

golf game, or whatever it would be. 

In my case, not only was I on his shift, but I was 

also in the transportation section, so I had occasion to 

drive him personally in the limousine for two years, at 

different stages. So -- so that’s probably why he has more 

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familiarity with me than maybe some of the others. 

People do rotate off of that. We stay. on average, 

on the Presidential Detail, four years so, after four years, 

people will rotate into other assignments, and so there will 

be new faces. 

So he generally talks to those that he knows. But 

as far as favorites, sir, I don’t - am not a favorite that 

I’m aware of. And I think he goes through what our chain of 

command would be a majority of the time. which would he the 

special agent in charge and those directly under him. 

Q When you were there, who were the special agents in 

charge? 

A Lou Merletti, who is now our director; Dave 

Carpenter, who is, I think, over at Treasury now, I think. 

These are alI gone. Excuse me. Not Treasury, State 

Department. I’m sony. Those are the two. And then, 

obviously, Brian Stafford, just before that: and now, Mr. 

Cockell. Now, I didn’t -- I did not work for Mr. Cockell in 

that capacity. 

Q So those people that you’ve just named were the 

head of the PPD during the time that you served at the White 

House? 

A Yes, sir. The agents will commonly refer to that 

as the special agent in charge. or SAC, or tbc detail. 

Q I want to talk to you now about recordkeeping that 

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factor involved and. therefore, we keep a lot. in my 

estimation, much more accurate records. 

But movements within, fmrn the mansion to the Qval, 

I mean. they’re pretty routine times, for the m0st part. 

Now, would we have a record of a movement from the 

Oval into the Roosevelt Room. which is directly adjacent? To 

the best of my recollection. I don’t think that we would 

necessarily keep an exact record of his movement into the 

Roosevelt Room. We would consider that to be West Wing. His 

movements within the West Wing, I don’t think we would 

denote particularly, rooms. 

Q Is there a report that’s made that’s calkd a PPD 

shift report? 

A The shift report, yes, sir. 

Q Are there reports or logs made caIled F-l movczttent 

logs? 

A F-l, F-l is -- yes, that’s common. but the agents 

do not keep those logs. The Uniformed Division would kq 

that log, and that would indicate an ekvator movement that 

would go from the diplomatic - from tbc ground floor up. 

Q Are them records entitled Fit Family locator 

command post logs, that you’re aware of? 

A We keep a log - not specifically. I think, to the 

best of my recoIlection of what they’re looking for hem is, 

is we have what is called a locator board in our command 

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In re: Grand Jury Proceedings July 23,1998 

Page 41 Page 43 

1 structure and. on that. in digital form. is the exact 1 in the _mnd jury room? 

2 whereabouts of the P&dent, First Lady, and Cbelsea at all 2 THE FOREPERSON: That is correct. 

3 times. 3 MR. PAGE: Thank you. 

4 And. as an example, if it wae the President into 4 BY MR. PAGE: 

5 the West Wing, it would say, “POTUS” or “Eagle, West Wing.” 5 Q Mr. Ferguson, several follow-up questions, if you 

6 It wouldn’t necessarily denote Oval Office. It may. But it 6 bear with me. 

7 all depends on who puts it in. 7 A Yes, sir. 

8 Q That’s a digital entry? 8 Q First, we talked about a presidential movement log. 

9 A It’s a digital entry. I’m not familiar with 9 A Yes, sir. 

0 another log outside that, sir. 10 Q In those records, if the President is with someone 

1 Q And then, finally, there are E-pass records, 11 at the time when he is making, or moving within the Oval 

2 correct? I2 Office or the White House complex, is the name of the person 

3 A Yes. sir. 13 who he may be with recorded in the movement log as well? 

4 Q Are there any other records that detail the 14 A No, sir. It’s strictly his movement. 

5 movement of the President or the Fist Family, that we’ve not 15 Q Now, we asked several questions of you regarding 

6 tanted about? 16 RF- 1, the exhibit, correct? 

7 A No. sir. I think you’ve covered it. There are 17 A Yes, sir. 

8 logs, obviously, for each protectee. being the President, the 18 Q And specifically, the Oval Office. The door inside 

9 Fit Lady, and Chelsea, independent of one another. So each 19 the Oval Office into what is marked on this diagram as the 

0 of those people would have an independent movement log. 20 Oval Office complex, that door I’m pointing to here -- 

l As an example, a shift report. if it’s a First Lady 21 A Yes, sir. 

2 shift, that shift report would, in fact, be -- contained on 22 Q -- which I’m now going to mark with a “D,” all 

3 tbe sbifi report is a movement log. 23 right? Do you see that “D” there? 

4 Q AR you aware of any other Secret Service agent, 24 A Yes, sir. 

5 wbetha a protective detail or Uniformed Division, or any 25 Q Is that a solid door that you can’t see through, or 

Page 42 Page 44 

1 otlzxz person that you are aware of that has any information 1 can you see through it because it’s glass or something else? 

2 relevant to tbe matters that we’ve been asking you about? 2 A It is a solid door, yes, sir. You cannot see 

3 A No, sir. I - I do not. I’ve never discussed 3 through the door. 

4 -- fast of all, this wasn’t of interest to me personally, 4 Q Does the door close automatically, or do you have 

5 until this story broke, and I had those recollections, SO I 5 to pull it shut? 

6 would have had no reason to have had a conversation about 6 A No, sir, you would have to manually close or open 

7 &an. 7 that door. 

8 MR. PAGE: If you give me just a minute. I may have 8 Q Can you tell us approximately the distance between 

9 another question. 9 the surveillance position, Ir or where you wfze when you 

0 THE WITNESS: Yes, sir. 10 saw the President and Monica Lzwinsky approach that door into 

1 MR. PAGE: Thank you. 11 tbe Oval Office complex? 

2 Mr. Ferguson. could you step outside for just a 12 A Yes, sir. I was just a few feet from the window. 

3 moment? 13 I had actually moved past the comer, because I didn’t see 

4 THE WITNESS: Certainly. 14 him initially, so I moved a few feet, and that’s when I 

5 MR. PAGE: Thank you. 15 observed them going into that door area. 

6 (Witness excused. Witness recalled.) 16 Because I - he may have been approaching it, but 

7 MR. PAGE: Mr. Ferguson, you’re back in front of 17 my first reaction was, I expect to view him immediately at 

8 the grand jury. And is it correCt that - 18 the desk. and he wasn’t tlxzz, and then I moval a few more 

9 THE FOREPERSON: And you understand you are still 19 feet. as I was looking, and then I saw him and who I believe 

0 under oath sir? 20 to be Ms. Lewinsky moving, bow many feet? It was like - 45 

1 THE WITNESS: I do, yes. 21 feet. That’s to include the Oval Office. 

2 THE FOREPERSON: Okay. 22 Q Approximately 45 feet? 

3 MR. PAGE: And is it correct that we have a quorum? 23 A Approximately, yes. sir. 

4 THE FOREPERSON: We have a quorum present. 24 Q You didn’t measure by tape? 

5 MR. PAGE: And no unauthorized persons are present 25 A No, sir. 

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Q It’s an estimation? 

A That’s correct. 

Page 45 

Q And )-OS haven’t been there in a while? 

A Welt, I don’t think it’s changed. But I’ve never 

measured it across. I’m assuming. That’s an approximation, 

Sir. 

Q Can you tell us what time of day it was? Morning, 

noon? 

A I can give you my best guesstimate, which I believe 

to be late morning. The reason I say that, I do recall it 

being daylight. I do recall it -- yes, sir, I -- before 2 

O’clock. I would say late morning, my best guesstimate, for 

that period of time. 

Q I want to ask you some questions about this 

interior door separating the Oval Office from the Oval Office 

complex. 

Is it routine for that door to be open while the 

President is inside the Oval Office, or closed? 

A Routine. I have seen it closed more often than I 

have seen it open. In other words, I have seen it both ways, 

but the most routine way would be closed. 

Q You testified that you had been in that Oval Office 

complex, and I believe including the study, several times? 

A Many, many times. 

Q Is that pursuant to your job -- 

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A Yes, sir. 

Q -- to check out the+ area in advance? 

A Not normally during advance. but I would be in 

ibex for one reason or another. But I’ve been in that area 

many, many times. 

Q All rigbht. Give us a reason that you would be in 

that area. 

A other security operational procedures would warrant 

me to be into tkt area occasionally. Let me say this. not 

wkn tk President was in tk Oval. This would k when k is 

removed from tk Oval. not during tk period of time k would 

ktkre. 

Q Well, fin& do you know whether it is more likely 

that that door that w&ve been talking about, between the 

Oval Office and tk Oval Office complex on this diagram, is 

more likely to k closed wkn tk President has guests. or is 

it - 

A It is more likely that the door would k closed. 

Q Wknkhasaguest? 

A I have to think. I don’t - when we say “guest,” 

sir, are you talking in an official capacity, friends of his? 

Q Let’s separate them, if tk answer is different. 

A I have had occasion, wkn k had personal friends. 

and have had an obsavation over the years -- now. this is 

not -- you mean specifically to this particular President, I 

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Q Yes. I guess we’re really asking about habit. 

A Normally, that door would be closed. 

Q With personal friends? 

A Yes, sir. And the reason I say that is that, 

unless he has gone, normally gone back into that for a 

reason, and had left it open, it would not normally be open. 

As an example, when we would bring the President 

over in any situation, that door would normally be closed. 

Q Going back to the two dates that we’ve been talking 

about, on either occasion, did Monica Lewinsky have anything 

with her? 

A Not that I recall. 

Q Senior agents are assigned to the PPD, correct? 

A That’s correct. 

Q And where does the Secret Service get new agents 

from? 

A For that detail? 

Q Correct. 

A They would come from - we maintained 50 what we 

called field off&s, and within that field off&z, and 

different divisions, once they’re in service seven to 10 

years, they would become available for a protective 

assignment -- Vice Presidents, former Presidents, dignitary 

protective divisions, a majority. 

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The Presidential Detail is generally more of a 

hand-picked group from within the Secret Service. It’s not a 

position that you apply for. You’re selected for that 

assignment. 

Q The Oval Office has a number of windows that look 

out to the grounds of the White House complex, correct? 

A Yes, sir. 

Q The study and the pantry area located within the 

Oval Office complex in RF-1 is more private, comt? 

A Yeah, that’s correct. 

Q Than the Oval Office? 

A More - yes, sir. As a matter of fact, we consider 

that to be the President’s private study, is how we refer to 

it normally. 

Q Arethereanywindowsfromthesouthernwallhere 

on the bottom of RF-l, by the study and the Oval Off& 

complex, that look outside? 

A There are. You have them denoted here, 1,2, and 

obviously 3, and with the. doorway. 

Q I wanted to go back to one last issue. And that is 

when you believe, to the best of your recollection, this 

occurred, not with regard to the month, season, but with 

regard to the year. 

Is it your testimony that you’re still uncertain, 

‘95 or ‘96? I 

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A It is, sir. The -- I tried to give you my best 

judgment, and I just don’t have a specific recollection of 

that. 

Q But you do have a recollection of Monica Lewinsky 

having a pass? 

A She would have had. She couldn’t have come to that 

area without out. Do I specifically recall that? No. But 

routinely, in everything that we’ve ever been trained to do, 

particularly into those areas, we would never have allowed 

anyone into those areas that were not properly identified. 

I can never remember a situation, in the history of 

the service, where proper identification -- particularly into 

the most secure area in the world, tbe way we see it, most 

sensitive -- would be anything other than that. 

So one of those two passes would have been the 

norm. To the best of my recollection, there was nothing 

outside of that norm, which would indicate to me that she 

would have had the appropriate pass. 

Q And, if she lost her pass, in April of 1996 -- 

A Okay. 

Q -- because she transferred from the White House to 

the Pentagon -- 

A Yes, sir. 

Q -- it makes it almost impossible, does it not, 

that these observations that you’ve testified about occurred 

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eight months later, in December of 1996? 

A She could come in on what is called an appointment 

pass. But an appointment would have had to have been made. 

She would have had to show proper identification at the 

gates, be screened like anyone else coming into the Oval 

Office complex. 

That appointment would have had to have been 

acknowledged, and would he in what is called our WAVE center, 

with that appointment, because that would have -- that goes 

to -- now you’re taIking about things within the Secret 

Service that would have occurred. 

So that appointment would have been noted. and she 

would have been issued a red pass, or whatever color we used 

at the time, with an “A.” which stands for appointment. Even 

that would have been proper crakntialing. We had a specific 

color for the West Wing, for that period of time. 

So I would have been more suspect of an appointment 

pass, which is not a permanent pass, if you will. An intern 

certainly is. We have a permanent passholder, which is. 

We even have a “I’,” which stands for temporary, 

which is a permanent passholder who. for one reason or 

another, didn’t bring their pass that day. kft it, you know, 

for whatever reason. But those 5% people &at. in fact we 

know work there, that are issued by the Secret Service. 

Now, with that in mind. could it have been a 

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different date because of that situation? I wouldn’t have 

know that until you told me. It certainly could have been 

the occurrence. But I couldn’t give you a more specific 

recollection. 

MR. PAGE: All right. 

A JUROR: I have one more question, if I might. 

Previous Presidents have had means of automatically recording 

conversations in the Oval Office. Does President Clinton 

have any means that you know Of. for recording automatically 

or manually, convasations that occur in the Oval Office, or 

in that area? 

THE WlTNE!?S: I’ll be more than happy to address 

that issue, if you can - if I could beg your - give me two 

minutes. I’d like to speak to counsel in regards to that. 

Let me ask you this sir. When you say does the 

President personally have a way to record conversations -- is 

that correct. sir? 

A JUROR: I guess my question is, are there 

recordings of conversations that occur in the Oval Office, 

whoever makes them? 

THE -S: I’ll be more than happen to answer 

that question, but I would like your indulgence for just one 

minute, so that I could clear an issue with our legal 

counsel. 

Certainly. I’ll answer that, but I would like a 

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

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1 moment to do that, if you don’t mind - 30 seconds. 

2 MR. PAGE: All right. 

3 THE WITNESS: Excuse me. 

4 (Witness excused. Witness recalled.) 

5 THE FOREPERSON: We’re back on record again. 

6 MR. PAGE: And with a quorum and no unauthorized 

7 people, correct? 

8 THE FOREPERSON: That is correct. 

9 MR. PAGE: Thank you. 

0 THE WITNESS: Thank you. I apologize for tbe time. 

1 THE DEPUTY FOREPERSON: And you are still under 

2 oath sir. 

3 THE WlTNESS: Yes, sir. To make sure I understand 

4 it correctly, your question is. does the President of the 

5 United States have the ability to manually or automatically 

6 tape conversations within the Oval Office; is that correct, 

7 sir? 

8 THE WITNESS: Yes. 

9 THE WITNESS: To the best of my knowledge, he does 

10 not. 

!I MR. PAGE: All right. Mr. Ferguson. Barring any 

12 other questions. thank you for -- 

13 A JUROR: I have ooe. How was she dressed that 

14 day, from what you saw? 

:5 THE WITNESS: I was asked that in the last grand 

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A JUROR: Jeans, dress, what? It was an off day. 

light? 

THE WITNESS: Yes, ma’am. I know for a fact x wa 

a Saturday. I do recall that. But how she was -- most 

staffers, on a weekend, do not dress as they would during *& 

business week, to include the President. He will oftengo to the Oval, on a weekend, for hours at a time, in jm 

or, you know, down clothing, as we would describe it. 

But I -- I really don’t have a recollection how she 

was dressed that day. 

THE FOREPERSON: Does anyone else have any 

questions? 

(No response.) 

MR. BENNETT: We ask that he be excused. 

THE FOREPERSON: You’re excused 

(‘Ihe witness was excused.) 

(Whereupon, at 3:21 p.m., the taking of the 

testimony in the presence of a full quorum of the Grand Jury 

was concluded.) 

l **** 

!/ 

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c l- 
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1119 

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

- 1 - 

OFFICE OF THE INDEPENDE!W COUNSEL 

Date of uanscription 2/23/98 

DEBRA SUSAN FINERMAN, white, female, .date of birth 

w place of birth _, Social Security 

7 _b, was apprised of the official identity 

of the interviewers and the nature of the interview. Also 

present for the interview, conducted at the Office of the 

Independent Counsel (OIC), 1001 Pennsylvania Avenue, Northwest, 

Washington, DC, were Associate Independent Counsel MICHAEL EMMICK 

and FINERMAN's attorney, STEVEN D. GORDON. FINERMAN was 

interviewed under a cooperation agreement between FINERMAN and 

the OIC, a copy of which is attached to this FD-302. The 

information provided herein attributed to LEWINSKY is what 

LEWINSKY told FINERMAN. FINERMAN provided the following 

information: 

FINERMAN is a journalist and writes for the magazine 

p ,apitol Stvle. FINERMAN graduated from the University of 

California at Los Angeles with a degree in pre-med and political 

science. FINERMAN works from her homes in Warrenton, Virginia 

and Washington, DC. FINERMAN advised she spends approximately 

twenty pert of her time at the family's Washington, DC 

residence, 

FINERMAN described her relationship with her niece, 

MONICA LEWINSKY, as being a close companionship. FINERMAN 

advised she speaks with LEWINSKY once every three weeks at a 

minimum. FINERMAN advised MONICA LEWINSKY and her mother, MARCIA 

LEWIS, FINERMAN's sister, are close friends. LEWINSKY would not 

bare her soul to her mother. FINERMAN advised LEWINSKY and LEWIS 

were close because they lived together. LEWIS.has a key to 

FINERMAN's apartment. 

LEWINSKY told FINERMAN about going to a birthday party 

for President WILLIAM JEFFERSON CLINTON on the White House lawn. 

LEWINSKY said that CLINTON was so ni@e and that LEWINSKY thought 

CLINTON liked her. LEWINSKY then advised that CLINTON came to a 

birthday party for someone in LEWINSKY's office at the White 

House. LEWINSKY advised that CLINTON smiled at her and that he 

kept looking at her. LEWINSKY was upset that a co-worker said 

that CLINTON never came to the offices for birthday parties, 

indicating the co-worker may have been aware of CLINTON's eye 

contact with LEWINSKY. 

InvcJliration on 2/23/98 at Washington, DC File # 29D-OIC-LR-35063 

by ::: v-m Date dictated 2/23/98 
1120 

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

29D-OIC-LR-35063 

Continuation of OIC-302 of DEBRA SUSAN FINERMAN ,On 2/23/98 ,page 2 

LEWINSKY said that EVELYN LIEBERMAN was a mean woman. 

LEWINSKY indicated she was reprimanded by LIEBERMAN for walking 

in a hallway near the Ova$Office. LEWINSKY said that CLINTON 

would call LEWINSKY in her office and tell her to walk by his 

office and wave to him as she walked by. LIEBERMAN labeled 

LEWINSKY a stalker. LEWINSKY could not tell LIEBERMAN that 

CLINTON had asked her to walk by, so she was put in a bad 

position. 

The only sexual contact FINERMAN knew of specifically 

between LEWINSKY and CLINTON was.one incident, which LEWINSKY 

told her about. LEWINSKY and FINERMAN were having coffee, 

something they often did on Sunday mornings. FINERMAN described 

LEwINSKY as being excited and anxious to tell FINERMAN that she 

saw "him" again. In the context of this conversation and other 

conversations FINERMAN had with LEWINSKY, FINERMAN knew IIhirnl' to 

mean CLINTON. LEWINSKY said it was really weird, but they fooled 

around in a little room off of the Oval Office and CLINTON 

to the effect of "yuck." 

FINERMAN responded by saying something 

Because of FINERMAN's response, 

LEWINSKY did not provide further details to FINERMAN of this or 

other sexual encounters LEWINSKY may have had with CLINTON. 

FINERMAN advised she believes this conversation took 

place within a week of the sexual encounter described above. 

FINERMAN advised she believes LEWINSKY was working at the White 

House when this conversation took place. FINERMAN advised that 

LEWINSKY would go to the White House to visit CLINTON on weekends 

when there were fewer people there. 

LEWINSKY told FINERMAN that in July of 1996, she went 

to the White House to visit CLINTON on a weekend. CLINTON and 

LEWINSKY had a long talk. CLINTON told LEWINSKY that they could 

not continue their physical relationship as he had to be I'good.It 

CLINTON told LEWINSKY that his advisers told him that he could 

not have any more llbimbo" eruptions. FINERMAN assumed that this 

was because of the upcoming Presidential election. LEWINSKY 

understood this and also thought that she would be working at the 

White House again after the 1996 election. 

FINERMAN is familiar with a White House "butler" named 

NELL. LEWINSKY said that NELL would give her White House M&M 
1121 

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

29D-OIC-LR-35063 

Connnuation of OK-302 of DEBRA SUSAN FINERMAN .On 2/23/98 . Payee 3 

candies, Air Force One souvenirs and other trinkets. On one 

occasion, LEWINSKY, giggling, told FINERMAN that NELL had a 

"secret." LEWINSKY then explained that NELL knew about the 

physical relationship between CLINTON and LEWINSKY. LEWINSKY 

said that she and NELL would go to dinner, and remained friends 

after LEWINSKY left employ at the White House. 

FINERMAN advised that she felt sorry for LEWINSKY 

because LEWINSKY did not have any friends at the White House and 

felt ostracized by some people at the White House. LEWINSKY was 

known by some as the "stalker." 

FINERMAN advised that MARCIA LEWIS knew about 

LEWINSKY's relationship with CLINTON. FINERMAN told LEWIS about 

the physical relationship. LEWIS may not have known the details 

before FINERMAN told her, but she knew LEWINSKY was emotionally 

involved with CLINTON. FINERMAN believes LEWIS understood the 

physical nature of the relationship. LEWIS knew about BETTY 

CURRIE's relationship with LEWINSKY. 

I*4 &.i 

LEWINSKY told FINERMAN that LINDA TRIPP said TRIPP knew 

CLINTON. LEWINSKY said TRIPP told her that TRIPP was psychic and 

a witch. LEWINSKY said that TRIPP advised that LEWINSKY's 

relationship with CLINTON was different than any of CLINTON's 

other relationships. FINERMAN advis?d that LEWINSKY was not into 

sorcery. 

FINERMAN advised that LEWINSKY was very careful about 

mentioning anything about the White House when in public. 

LEWINSKY said she told some friends in Los Angeles about her 

relationship with CLINTON. FINE- has met ASHLEY RAINES. 

LEWINSKY told RAINES about her relationship with CLINTON. FAINES 

did not approve of LEWINSKY's relationship with CLINTON, but 

still remained LEWINSKY's friend. LEWINSKY's friend KATHRYN 

(phonetic) Last Name Unknown (LXU) also knew about LEWINSKY's 

relationship with CLINTON. 

FINERMAN advised that WALTER KAYE and his wife, SELMA 

KAYE, visited Los Angeles a lot. Approximately twelve years ago, 

MARCIA LEWIS's friend, ALISE SPILKER, introduced LEWIS and 

FINERMAN to WALTER KAYE. LEWIS, FINERMAN and WALTER KAYE became 

friends and social acquaintances. 
1122 

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29D-OIC-LR-35063 

Continuation of OK-302 of DEBRA SUSAN FINE= ,On z/23/98 . Page 4 

KAYE may have guessed about CLINTON's relationship with 

LEWINSKY. KAYE would make comments about CLINTON's habit oz 

flirting with women. KAYE was friends with people in the White 

House who did not like LEWINSKY. 

WALTER KAYE's grandson served as a White House intern 

at one time. FINERMAN asked WALTER KAYE to put in a good word 

for LEWINSKY during her application process to become a White 

House intern. WALTER KAYE has a lot of friends at the White 

House. 

Sometime after LEWINSKY left employ at the White House, 

LEWINSKY received telephone calls from CLINTON at her home late 

at night. FINERMAN believes the telephone calls occurred in 

January or February of 1997. LEWINSKY did not explain what was 

discussed during the telephone conversations. FINERMAN has never 

heard answering machine tapes with CLINTON's voice on them. 

CLINTON would call from his bedroom when HILLARY CLINTON was not 

around. 

In February of 1997, KAYE hosted a party in New York 

for CLINTON. LEWINSKY expressed an interest in going and asked 

FINERMAN if she could get LEWINSKY tickets. FINERMAN asked KAYE, 

who responded that FINERMAN's niece was very pushy. FINERMAN 

retorted that it was CLINTON telephoning LEWINSKY late at night, 

not the other way around. KAYE appeared shocked. 

KAYE is friendly with DEBBI SCHIFF and MARSHA SCOTT, 

two people LEWINSKY said were ex-girlfriends of CLINTON/s. 

FINERMAN has never heard the term "graduate" used to describe an 

ex-girlfriend of CLINTON's. LEWINSKY told FINERMAN that SCHIFF 

has been transferred to the State Department. . 

LEWINSKY was told she was transferred out of the White 

HOUSE because the personnel allotment of her office was being 

restructured. LEWINSKY told FINERMAN this was the only reason 

for the transfer. FINERMAN believes LEWINSKY did not connect the 

rumors about her being a stalker to her transfer. FINERMAN does 

not know if KAYE had anything to do with LEWINSKY getting a job 

at the Pentagon. 
OK-302a (Rev. 8-19-941 

1123 

29D-CIC-LR-35063 

Connnuation of OK-302 of DEBRA SUSAN FINERMAN .On 2/23/98 , Payee 5 

LEWINSKY was sad to leave the White House. LEWINSKY 

liked her job at the Pentagon, but the hours were long and there 

was a lot of travel. LEWINSKY was not suited for her position at 

the Pentagon. 

CLINTON told LEWINSKY she would return to employment at 

the White House after the 1996 Presidential Election. CLINTON 

told LEWINSKY that SCOTT would help LEWINSKY find a job at the 

White House. LEWINSKY had an interview with MARSHA SCOTT at the 

White House in 1997. SCOTT told LEWINSKY there were no jobs 

available at the White House. 

In June of 1997, MARCIA LEWIS moved to New York City. 

LEWINSKY decided she would move to New York as well. FINERMAN 

believes CLINTON arranged an interview for LEWINSKY at the United 

Nations. LEWINSKY felt the United Nations' position was too much 

like her job at the Pentagon. 

FINERMAN found out in November of 1997, that LEWINSKY 

was leaving her job at the Pentagon. 

FINERMAN and LEWIS were walking down Fifth Avenue in 

New York City when LEWIS said that LEWINSKY had a meeting with 

VERNON JORDAN. FINERMAN was aware of two meetings LEWINSKY had 

at JORDAN's office. One meeting was a breakfast meeting, the 

other was during lunch. FINERMAN is aware that LEWINSKY had 

other interviews. Until LEWINSKY got a job offer, FINERMAN was 

concerned that CLINTON would just dump LEWINSKY. FINERMAN was 

aware of LEWINSKY's interviews at AMERICAN EXPRESS and REVLON, 

though FINERMAN was not familiar with the name MCANDREWS & 

FORBES. LEWINSKY told FINERMAN about her job offer from REVLON, 

and LEWINSKY appeared to be happy about it. 

WALTER KAYE had told FINERMAN and LEWIS that all the 

telephones in Washington, DC were tapped. FINERMAN advised that 

LEWIS came up with the code name "GWEN" when referring to JORDAN 

during telephone conversations. 

The only conversations FINERMAN recalls about the PAULA 

JONES lawsuit was related to LEWIS's, LEWINSKY's and FINERMAN's 

opinions. FINERMAN thought JONES' suit had merit; LEWIS thought 

it did not, and LEWINSKY thought CLINTON should settle it. 
1124 

OlC-3CCa (Rev. 8-19-94) 

29D-OIC-LR-35063 

Conunznon of OK-302 of DEBRA SUSAN FINERV-9N .~n z/23/98 .Page 6 

FINERMAN may have heard LEWINSKY mention KATHLEEN 

WILLEY's name. FINERMAN did not understand the story about 

WILLEY and CLINTON. 

FINERMAN advised that she knew LEWINSKY had to go to 

something court related a week before LEWINSKY went, and knows 

LEWINSKY had to sign something, but FINERMAN was not aware it had 

anything to do with the PAULA JONES lawsuit. FINERMAN did not 

know anything about a witness list. FINERMAN knew LEWINSKY had 

to see a lawyer named FRANK CARTER. FINERMAN did not know of the 

relationship between CARTER and JORDAN. FINERMAN is not aware of 

the fee arrangements between LEWINSKY and CARTER. 

FINERMAN only knows of one meeting between CARTER and 

LEWINSKY, but is aware of several telephone calls between the 

two. 

FINERMAN did,not see LEWINSKY often in late December of 

1997. In January 1998, FINERMAN was with LEWIS in New York when 

LEWINSKY called to ask LEWIS to come to Washington because the 

Federal Bureau of Investigation (FBI) wanted to talk to LEWINSKY. 

LEWIS told FINERMAN that she did not want FINERMAN to know why 

LEWINSKY was meeting with the FBI. When their train arrived in 

Washington, DC, FINERMAN went to her apartment at the Watergate. 

The following day, LEWIS told FINERMAN about TRIPP 

taping TRIPP's telephone conversations with LEWINSKY. 

After January 16, 1998, FINERMAN did not talk to 

LEWINSKY or LEWIS about LEWINSKY's relationship with CLINTON. 

LEWIS did not want to testify before the grand jury. FINERMAN 

was not aware that LEWIS was asked to be interviewed by the OIC. 

FINERMAN is not familiar with the names BOB NASH or 

ERSKINE BOWLES. FINERMAN knew that LEWINSKY was friends with 

BETTY CURRIE. FINERMAN remembers when CURRIE's brother was 

killed, LEWINSKY sent balloons. LEWINSKY said she would call 

CURRIE to see when LEWINSKY could visit CLINTON. 

FINERMAN saw a hat pin CLINTON gave LEWINSKY, which 

FINERMAN believes was in 1996. FINERMAN also remembers some 

"junky souvenir" items CLINTON gave LEWINSKY in the summer of 
1125 

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

29D-OIC-LR-35063 

Cononuation of OIC-302 of DEBRA SUSAN FINERMAN .On 2/23/98 .Page 7 

1997. Included in that was a canvass bag with the logo of the 

"Black Dog" (a "tourist place") on it, a beige cotton shirt and a 

t-shirt with the "Black Dog" on it. FINERMAN saw a hard cover 

version of "The Leaves of Grass," which LEWINSKY said CLIN'XN 

gave her. FINERMAN did not see an inscription in the book. When 

LEWINSKY worked at the White House, LEWINSKY showed FINERMAN a 

cigar that LEWINSKY said belonged to CLINTON. 

FINERMAN is aware of LEWINSKY giving CLINTON some ties. 

FINERMAN has read the book titled r'V~~", and knows it is about 

telephone sex, but does not know‘the book in relation to CLINTON. 

FINERMAN is not aware of a compact disc CLINTON gave LEWINSKY. 

FINERMAN remembers LEWINSKY buying a book in Annapolis, Maryland, 

and giving it to CLINTON for his birthday. LEWINSKY gave CLINTON 

a ceramic frog. FINERMAN is not aware of LEWINSKY giving CLINTON 

an audio or video cassette. 

In 1997, LEWINSKY took out a "personal" advertisement 

for Valentine's Day in the Washington Post, and directed it to 

CLINTON. LEWINSKY told CLINTON about the advertisement. 

FINERMAN is not aware of a dress of LEWINSKY's with a 

stain on it. LEWINSKY referred to CLINTON as the "creep" the 

"big creep" and l'Bubba." FINERMAN does not recall LEWINSKY 

referring to CLINTON as "handsome." 

Someone at the White House made a derisive comment 

about MARCIA LEWIS's book "The Three Tenors" being a "kiss and 

tell" book. LEWIS said she was going to send.a copy of the book 

to the White House and FINERMAN may have suggested sending a copy 

of the review of the book in the New York Times Book Review. 

FINERMAN is not aware of any notes or cards exchanged 

between CLINTON and LEWINSKY. FINERMAN did not hear of an 

incident involving CLINTON and LEWINSKY in the White House movie 

theater. LEWINSKY did tell FINERMAN about the time CLINTON 

invited LEWINSKY to watch a movie with CLINTON and others in the 

theater, but LEWINSKY turned the offer down because she did not 

think it was a good idea. LEWINSKY was still working at the 

White House at the time. 

1127 

Debra Finerman, 3/l 8/98 

OIC Deposition 

Page 2 to Page 

CONDENSED TRANSCRIPT AND CONCORDANCE 

PREPARED BY: 

OFFICE OF THE INDEPENDENT COUNSEL 

1001 Pennsylvania Avenue, N.W. 

Suite 490-North 

Washington, DC 20004 

Phone: 202-514-8688 

FAX: 202-514-8802 
1128 

3118198 

Page 5 

;. A Yes. 

1:. Q Are there any queshons that 

: : : those righti or oNbokgatrons as I ve described Y 

ou have ayu! aiy of 

hem to you 

__ Q What I would like to do is .ust make a couple of 

::.matters clear on somewhat of an informa 1 basrs. What I mean 

:J -by that is, we are goin to be talkin 

: 5 : may be somewhat d il? ~cuft for you. gi 

about some thongs tha? 

ou are here with a couc, 

1-1 reporter whom you dont ’ know. Youve ’ met me on one prior 

: 5 : occasion, I believe. 

5 But I 

!3 ithe subject ma ti er IS more explicrt than you might ordinanly 

.ust wanted to say, bear with us if some of 

__ -. : like to talk about publicly. 

.._. A 

ii<iresponse.) 

(Wtnetinodded indicating an affirmative 

:2i: Q That is the introductory material that I would kke 

:I 5: to have gone over with you before we get started. Unless yw 

Page 3 Page 6 

[iI PROCEEDINGS 

~2 !WHEREUPCfN ’

!3! DEBRA FINERMAN 

{I 1 having been called for examination by the Office of the 

rillndependent Counsel, and having been first duly sworn by the 

::: have any 

:: : the suble .3 

uestions. well ’ jump right in and ask questions on 

matter. 

:3: A Okay. 

::: Q What I would like to ask first is for you to 

:z:describe your familial relationship with Marcia Lewis and 

:c:with Monica Lewmsky. 

(6: notary, was examined and testified as follows: ._. A 

17) EXAMINATION BY COUNSEL FOR THE INDEPENDENT COUNSELniece. 

Marcia Lewis is my sister and Monica Lewinsky is my 

:?! BY MR. EMMICK: 

! 3 : Q Would;ou state and sgell~r name for us? 

A Debra merman. D-E- -R F-l-N-E-R-M-A-N. 

What I would like to start wdh, Ms. Finerman, is 

5 Q Let me ask you to describe more colloquially and 

i G jmore in an informal fashion what kind of a relationshrp you 

:;: 1 have with Monica Lewinsky. 

A 

:<:and ‘ Im ’ ve 

Well. Ive ’ known Monica since the day she was born 

8 

fond of her. 

Do you have a relationship with her that you would 

:!l ldescribe a; a clcz: relationship? 

..;: 

i.:- 

..a, ’ A Yes, Ido. 

. ‘ 2’ 

.A_, Q Who is that? 

.^nl ,-_! A Steve Gordon. .^. 1 

_--. Q Is he somewhere in the vidnity? 

!:2: A Yes. He is outsrde this room. 

Q So 

~~~!consult with him wit 

ou understand that if you feel a need to 

4 regard to any of the questions that I 

: 25 ! ask, you can simply say, I wonder if we could stop for a 

_ __ ~___ -__ 

Page 4 

[ : : minute whp I cyDensS.Ult with my attorney? 

,^> L-1 

0 All right. Second, as a general matter, you, like 

i:;all witnesses, have a Fifth Amendment tight to refuse to 

r5lanswer any questions that might tend to tncnminate you. 

[~~Now. in thus case, your attorney and. I have discussed and 

~7 1 agreed upon what IS called transacbonal immunrty for you. 

: 9: Are you aware of those discussions? 

!?: A Yes. 

[lOI 

Ii:] ’ *‘I @position ‘ Exhibit DF 1 was 

Ii:' marked for Identification.) 

[13i BY MR. EMMICK: 

Q I have in my hand a three-page document that we 

I :: i have labeled as DF 1. Just so that you know, that means 

11 E y Debra Finerman #l_ It is a copy of what is called 

[ 17; Cooperation/Immunity Agreement, Debra Finer-man. Do you 

I i 3 I recoonize that? 

ilSj - A Yes. 

Q That is a document that describes the immunity that 

I:E i you have and, on the flip side of that, describes the 

f 1:: cooperation that 

(2x1 Immunity. Is tha Y 

ou have agreed to grve in exchange for that 

correct? 

c-4; A Yes. 

125; Q All right. Next, let me describe for you an 

-A, 

.._. 6 L& direct your attention to, sa 

:f? j years, that is, from 1993 or so. ,Have you had Y? requent 

the last three 

.:z-conversatiins ~;;hlontca Lewrnsky? 

__: 

.I. 

-. 

-“:oerson? 

6 ‘ And have some of those conversations been rn 

--.r 

‘^j’ 

.--> A Yes. 

-14: Q And some by telephone, I take it? 

.__. A Hmm, yes, some of them. 

Page 7 

Q About how often would you say you have met with 

j: j Monica Lewinsky? Is there a wa 

:j!average, or some ballpark about Y, f; 

that ou can give us some 

ow o en you meet with her? 

A Varyin . dependent upon circumstances. Wtiin that 

:iitime, maybe not week 9 y, 

::iwhat 

Q 

maybe twice a month on the average. 

Fine. And when you mentioned earlier that you have 

: 3 j woul dy 

ou describe as a close relationship with Ma. Lewinsky. 

youtll uqezhat ou mean by a close relationship?. 

.3! Wy 

:: 1: sometimes we 

e go out to movtes together sometimes and 

o out for coffee and famil 

%nd do you sometimes tal 1: 

events. 

. . , ~ Q 

i:_imatters with her? 

about somewhat persona 

l3) A Yes. 

:14: Q When you have those discussions of personal 

:: 5 1 matters, are the 

A Jes sure. 

generally with just you and Ms. Lewrnsky? 

::j; 

3-1 

f 13 imoment, 

Q We will ‘ get into more detail about that in ust ‘ a 

Would you describe for us the relationship tha 1 

: : 5 1 Monica Letinsk has with her mother, your sister? 

.-_. Sy ure She lrves with her mother, althou 

:s f i didnt ’ intend it to be that way permanently. But when s 4 

h they 

e 

:::jfirst moved here to Washington, she moved in with her mother, 

:: 3: thinking she would then meet kids her age and she would get 

_:; roommates and move out. But that drdn t ha en. 

.--, Q That would have been in 199 lf 

Page 2 to Page 7 
1129 

BSA Debra Finerman, 3118198 XMAX(2) . 

Page 8 

. 

I ‘ with ‘ her mtther. %nd her -- what was the question, is she 

Ri ht That didnt ’ happen. So she has stayed 

Page 71 

: : I it. It didnt ’ mean a lot to me 

._: 

i;:incident, 

Q Let me then direct your azention :o another 

: ? ’ close with her mother? if you will. in fact another birthday par& that 

Q Or just describe her relationshrp. My followup 

j; -question would have been, how close are they. 

:- A Right. I think that they are close, as a mother 

ii j and daughter usual1 are. 

0 Are t & ere differences in the kind of relationshrp 

:;:that you have with Monica than the kind of relationshrp that 

: 5 Monrca has with her mother? 

A Hmm. Sure. I dont ’ discipline Monica as her 

I: : mother would. I dont ’ pay for her thongs. Im ’ more, I 

15: uess, closer in age to her; not a contemporary, but I think 

1:. w at she feels that I am closer in age ma 

0 Would you regard yourse r f as more of a confidan:e. 

be. 

__ 

.:; : if you will? 

..-. A Yes. .- 

>- 2 ~~l?:p,i%r$%$lt%& ‘‘ might think that she 

:: J j could tell me thin sthat ’ I would want to hear, t at maybe 

-1:. her mother woul 80 n t be interested in. 

___: 0 Okay. Let me turn your attention then to the third 

!:<jrelationship there, and that is your relationship with your 

: 2 5 : sister. 

.?i. 

.--,, A Uh-huh. 

Page 9 

.-. 

- Q 

._. 

.-. A 

Would you describe that relationship? 

Q 

Very close, professionally and in our family. 

.-. What do you mean b professionally? 

:;‘ A Weve ’ always worke J together. We are writers and 

.s jwe are partners writing, and weve ’ always been,. Wefl, 

: E: always, meanin from when we started our wntrng career. 

0 

: 3 i mean by that? 

%rd personally close. Can you explain what you 

A Sure. Our father passed away when we were little 

: i i:girls. And when you have a father who asses away, it brings 

.::: you closer to your siblin s. So, she an 

: 1:. close in terms of her loo R- rng out for me. 

8 I have always been 

Im ’ seven years 

.: 3 : younger And in that way, we have always maybe relied on 

: :; : each other more than other siblings. 

.-- Q Does she sometimes talk with you about Monica? 

::z A Sure. 

Q And the problems that a mother might encounter with 

:tr ja daughteifor;;znple? 

;: 

,__: Q What I would like to turn my attention to next is a 

i i : discussion of what you know of Monicas ’ relationship with 

.:I President Clinton. 

-_ A Okay. 

Q What I would like to do is start off with a few 

I; j particular incidents and then proceed from there. 

Page 10 

. _*, A Okay. 

.-. 0 Let me ask you first if you know anything about a 

:j: birthday party that was thrown for President Clinton where 

j ; ; Monica rnaAde soose comments to you about that birthday party? 

-5.1 _-> 

Q Would you tell us about that, and I will ask 

!p jfollowup questions to clarify things. 

A Okay. As I recall, when she first became an 

izi intern I think she was invited along with all the whole 

: : 2 j staff, io a birthday party for Piesident Clinton, which I 

: :: : think must have been in August. And I think thats ’ where 

: :I- : they first maybe met. 

. i Well, anywa 

1 I; : and that he seemed a x9 

she told me that she first met him 

ratted to her or interested in her or 

: 15 : something. And in sort of an immature way, she said, oh, 

r -: hes ’ so cute and I think he looked at me. and that sort of 

fithing. ’

1:s: Q Now, is this something that she told you shortly 

: 12: after the bghda party? 

.^^. 

.--, 

._. Q 

i_!fabout that? 

&obablk yes. 

And at t e trme, did you think anything unusual 

i ‘ A No, not - well, I dont ’ know. I wasnt ’ sure 

f!; ~whether it was her imagination or he - I had heard that he 

,:sjoften looks at women in crowds. So, I didnt ’ think much of 

Pase 8 to Page 13 

I 4 : Monica may have describe3 to you of a coworker with Monica 

;; ‘ Do you remember the rnuoent I am speakrnq of; is: . A Yes. I do 

,_. Q Would you teil us what you recall Momca saying 

4 i about that incident’ I.. 

[ G ‘ ; A 

L;; J intern. 

Okay. Thus was later. I think she was still an 

I dont ’ think she was - Im ’ not sure whe:her she 

[ :: 1 was an employee or an intern. But there was a coworker of 

i 1: : hers who was having a brnhda 

[: 2 j are low-level people in the Whl 1 

party And thus was - these 

e House. 

And she told me that President Clinton had come by 

I iii to say hello, or somehow wash this person a happy birthday. 

~:h!which was very unusual. And the other people who worked in 

[I 7; that office commented on it and said something like. wow, 

I; 9 1 look, the President came 

And she commented to me - I think that was the 

Iiijtirne that she said, I think he came to see me and he was 

121 llooking at me and he was making it very obvious. , 

!I?21 Q And did that distress her as she was describing it 

jz3lto you or did it make her ha py? What was her reaction as 

rzq;she was describing this inc&nt? 

1251 A I remember dearly that she thought this was erther 

Page 12 

111 ina 

12 Itha ! 

propriate of him or would make other peopk notice, and 

would be not a good thing. 

:ijLewinsk 

Q Over the course of your conversations with Ms. 

[5 1 to descn & 

did you come to know that she used some nicknames 

President Clinton? 

[61 A Well, Ive ’ read about it. So. 

Q Did 

iii focusing here on w i! 

ou hear from her though? I am going to be 

! 9 1 this hittrng 

at things she told you prior to all of 

the news, if you will. 

[ISi A 

c I I ; later. 

She may have said Big Creep, but that was much 

r;:1 Q That was later? 

i??j A Much later. 

Q And when 

/ iiiestimate of when you sta 

ou say much later, can ou ive us a best 

:Islway? 

x ed hearing her describe i. rm 9 hat 

!:I ‘ A I think she jokin after 

: 1~ 1 she had already moved to the B 

ly referred to him that wa 

entagon. So, that would 15 e 

i I 4 I months later. 1~~ 1 

[2?1 Q And did she give any indication how she had come up 

~2; jwith that name, or why she wanted to refer to him as the Big 

;zziCreep? 

123’ A I think she was mad at him or disaffected or 

i ~4 i something like that. 

[25; Q Now let me ask you about gifts that you know of 

Page 13 

: 11 that Monica received from President Clinton. 

[I ‘ A Okay. She showed me a hatpin. 

:31 Q 

A 

Can you describe it at all? 

Yes. Well. It was kind of round. about that big 

i z i (indicating) and gold and rt may have had some enamel on 

; 6 i it. And then theres ’ a’ lonq thin part to it. Thats ’ how I 

i 7 j remember it. 

_ . 

i?: Q 

A 

How is it that you came to see this hatpin? 

She showed me. She said, look, look, I got a 

..~.. riiloresent. She was all exated 

0 Now, when she said she got a present, how is it 

I :t i that you connected the present with President Clinton? 

i131 A 

Cl 

Oh, she said. the President gave me this. 

Can you tell us where you were in order to see the 

ii:; hatpin? Was this at her apartment or - 

I161 A Her apartment. 

[iTI Q Can you tell us when this ha 

1191 A Oh, bo 

pened? 

I think it was some ? tme during the 

[ : 9 1 summer. a summer. & r I cant ’ really say. I just remember 

[ 2 o 1 that she used it and put it in a straw hat which .makes me 

[ 2 11 think it was some warm time of year, erther spnng or summer. 

Q 

1::1]96 ‘ or 97? ‘

Can you tell us whether rt would have been 95 ‘ or 

And just to help you bracket those times, 95 ‘

r:d~would have been the summer during which she started as an 

jzslintern; 96 ‘ would have been the time when she had been at the 
1130 

.a”_ ICb 

Page 14 

Debra Finerman, 3118198 XYAXN . 

i i ’ Pentaoon for only a couple of months; and 97 ‘ would have been 

1: jeight mantis or so ago. 

r3: 

Q 

I can guess. Im ’ sorry. 

Guessrng IS probably not the best practice But if 

1tj ou can give us your best estimate or your best belief, 

i 6) K avrng In mind that you dont ’ have much certainty. 

;:I A Okay. 96. ‘

,i(! Cl What other aifts from Presrdent Clinton do you know 

19 j about? 

A Okay. I know about a 

liy;Marthas ’ Vineyard, from Black Do 

[ 1: 1 a tavern or a hotel or something. B nd there was a T-shirt 

i 11i! and a kind of cotton dress, sleeveless, long cotton dress. 

: 14 1 And I thank some krnd of a bag, like a canvas bag. And, what 

Page 17 

: been ‘ workin at the Whrte House. Then after that, she would 

.- - have ‘ been a 9 

:- 

.-_ A 

the Pentagon. 

It was during the time she was working there. So. 

4 iaround that time. 

“_ Q The White House? 

r A Right, the White House. 

-1 ‘ Q 

i ! f the Presrdent? 

How drd she say she had obtarned thus crgar from 

3 A Hmm. She didnt ’ tell me. 

--. Q Okay. What did she say about the cigar? She JUS! 

: : ; : said. I have this crgar from the Presrdent? 

,:<;it to her 

A She said, look, look, I have this cigar. He gave 

iijjelse? 

(I.61 

!17i 

Okay. Then I also saw - 

Q Before we leave that topic. can ou tell us under 

[ : 3 jwhat circumstances you saw these items? An J naturally Ill ’

[:slask you when or what is your best estimate of the time you 

[IO;SSW it. 

[2i! A Okay. She showed me them in her apartment. And 

[ZZ Iwhen? The summer, this summer. 

[23! Q This summer? 

[241 A Right. 

[251 Q Thts would have been 97 ‘ then? 

Page 15 

I:! A Yes. 

Q 

i; 1 about them? 

And when she showed them to you, what did she say 

141 A She said, look. I got some presents from the 

[ 5 1 President. And she showed them to me and she was happy. And 

[ 61 Imust tell 

K 

ou. I was surprised that a man could pick out a 

r7ldress. sue a perfect size of a dress, which made me thank, I 

[ 3 iwondered whether maybe some aide, some woman had out 

[ 3: these things for hrm to give her, because its ’ very hard to 

prcked 

: 10 1 choose someones ’ size so accurately. 

;:?I Q Okay. Did she say anything more about those 

[ :z 1 presents a; she showed, them to you 

_. ,*3! No. I don t thank so. 

i;d‘ 0 You were about to mention some other items? 

[;5; A Right. And then he gave her a book, the Leaves Of 

! : 6) Grass, or whatever it is. leaves-of-something book. 

[I! ‘ Q 

A 

When did you come to know about that? 

,:j, _- I think it was around the same time. 

r:> Q The same time, being the summer of 97? ‘

A Summer of 97. ‘ - 

0 How did you come to know about that? Did she show 

c--,it to vou? t--, , 

i:3j A She showed it to me. 

i-_4, Q What did she sa as she showed it to 

I-i C-J. A She said, oh, loo Y, at thus beautiful boo ): 

ou? 

that the 

_ 

Page 18 

[ 11 President ave me. 

_I* 8 And did she say why the President had given her 

I;ieither the book or the other items? 

[41 A No. 

i5: Q What other items that were gifts? 

[ij: A 

Q 

I dont ’ think there is anything else. 

Let me ask you about one item that I think you 

! i i mentioned as we were discussing these items a cou le of weeks 

)91a o. You indicated during that inrtial interview - pro R er- 

/ iol In 3 ervrew. I believe we have been calling it - that she had 

:Ilia cigarthat- 

[I_; ‘

,--. i!?, t ~~h~$%sident had aivel her. 

[I41 A Yes. 

115: Q 

A 

Can you tell us how you came to know about that? 

Yes. Again, sometime she said to me, look, look. I 

1::; have a cigar, his ci ar. And it was, I think it wasnt ’

ila!smoked. It was jus 9 a cigar. And she had it in her room and 

rlglshe showed rt to me. But that was earlier than all of this. 

[Ic: Q Then lets ’ try to clarify the time as best we can. 

;-7:1 A Okay. 

[Z-7! 0 The ci ar time would have been approximately when? 

rz3!Again, I can help bra & et the time by indicatin that she was 

~24 !an intern during the summer of 95 ‘ unhl about R ovember. And 

;zslthen from November of 95 ‘ until April of 96. ‘ she would have 

OIC-Starr 

.__‘ ..- . 

::4; 0 Okay. 

.-II A I know that. But I dont ’ know what circumstances 

_~ .-5. 0 

::-:example? 

Was It a cigar that would be in a cigar tube, for 

--a> _ ,I A No. It was not in a tube. It was iust there. It 

i 1 I j was just a cigar 

’ 

._I? .--I Q 

No I donrthink ’ so. 

Was it in lastic packaging at all? 

Doyou ’ remember if it had a cigar band or any 

;2:j A 

1-11 Q 

iI;;little paperA- 

[24] 

;z;]package. 

I dont ’ remember. No. But I know it was not in a 

-_ 

II] Q Okay. When you started to describe under what 

[ 11 circumstances she showed you the cigar, you sort of made a 

[3lgiggling-type .motion with our hand and your mouth. Did she 

[ 4 1 seem to bigrg lrng abou It at all? 

[ziexcited and 

8’ h yes .I- She s alwa 

look ‘ what I have, 

y s like that. Shes ’ always all 

look 

: 7 1 boy, that sort ’ of attitude. 

ook what he gave me, oh 

!3j Q All ri 

9 

ht. 

; 91 know that she 

Well, lets talk about any gifts you 

ave o President Clinton. 

;:?I A %kay. I know she gave him some ties. And I know 

:: 11 she gave him a book Thats ’ recently. I think that was this 

[ :z 1 summer for his birthday. 

;13j Q All right. Lets go back to the ties. 

::;I A Okay. 

::51 Q And take it a bit at a time. 

. _ .-0, A Okay, sure. 

-7, ‘ _ 

12; 

Q How manv ties do YOU think she may have given him 

;:;i 

A I think two. . 

Q 

A 

And how do you know that she gave him these tres? 

Because she would say somethrng like, Im ’ watching 

ii: i him on TV today and hes ’ wearing my tie. Or, I watched him 

12 1 on TV, hes ’ wearing my tie. 

“3‘ Q 

i S 4 i timeframe? 

When would she have then grven him these ties, wha 

:Tjj A I think during the time she worked there and then 

Page 19 

; : 1 maybe when she was at the 

: 2 1 more than two. I dont ’ know. 

Pentagon. So. it may have been 

i31 Q Can ou describe the ties at all? 

i4] A No. r dont ’ know. 

:51 Q You started to mention a book that she had 

: 6 1 purchasedAzerhtf;:ast summer?’ 

I. ‘

i?; Q TJI us about that. 

(91 A She bought him - she happened to be in Annapolis, 

[loland she knew that he liked books about sailing or the Navy or 

[ 1 I 1 something. So, she bought him a book as a birthday present. 

II 1 ..-I Q Do you know what the book was? 

(131 A 

: 14 ;something 

No. Something to do with sailing or ships, or 

like that. 

(151 Q How did you come to know about this? 

1161 A She told me. 

Q Did she say that she had made a special trip to 

ii: j Anna olis? Or what were the circumstances under which she 

i:slboug!t this book? 

rn; ’ A I dont ’ know. I dont ’ think - I dont ’ know. 

;:I IEither she was there or something. For some reason she was 

,:zz 1 in Annapolis. 

Q When you sa she bought the book, did she 

!~i!specificai$,say;rh bought I -ty for the President? 

;251 

__-._ ~~ ~_ -___ 

Page 14 to Page 19 
1131 

Debra Finerman, 3118198 XMAXI4! 

Page 20 

0 

j i ; Presrdent? 

Did she say how she had given the book to the 

.~. 

[3: A No. 

0 Did you ask her anything about how she plans to 

i:jgive the book to the President, anything like that? 

is: 

i7’ 

E‘ ’ 

A 

Q %ay. What about any other gifts from her? 

A To hrm? 

[P! Q Yes. 

A Oh she bought him some lrttle thrn s like a frog, 

i ry: or a littie frog doll or somethrng, because she said w3 e kkes 

rlz:frogs. 

[?3’ 0 A frog doll. When you say a frog doll. do y;u mean 

i 14 : like a fabrii krnd of a frog, or do you mean a ceramrc fro 

;>:: I didnt ’ see it. I don t know what it was. 8 ome 

;I;! kind of a fi ure of a frog. I dont ’ know if it was ceramic 

i :T ior a stuffe 3 anrmal or what. 

;i3! Q And how did she describe to ou the fact that she 

: 191 had given him a frog of some kind? How,dr .dYthis come up7 

[ZO! A She robabl said somethrng like, I saw such a cute 

~2: 1 frog doll. so I ot It or the desident because he likes 

i~zjfrogs. 

2, p 

Somet In lake that. 

Q dhen did this conversation occur, or when did she 

i z i j give him ty frog? 

I?51 I dont ’ know. Im ’ guessing during the time that 

~___ 

Page 21 

t 1) she worke; at tgkLentagon 

I?’ 

[3; A But Y dont ’ know exactly. 

Q She would have been working at the Penta 

1 :i April of 96 ‘ all the way until the very, very end of ! ‘

r 6; So. tha!s ‘ a long period of time. Can you bracket 

37. 

wn 

it a bit 

from 

; 1; j conversation. 

; -12 :Q 

[?5i A 

r-n\ Q 

Im ’ sor I cant. ’ Its ’ just so insignificant. 

Okay. % ny other gifts that you can think of? 

That s all I can remember. 

Let me ask you about a book by the name of VOX. 

Okay. 

trhyuohu familiar with that book? 

What is the book VOX about? 

Its ’ a long book, I think about one phone 

Okay. 

I read it. I dont ’ remember it that clearly. 

Have you talked with Monica about that book? .--. 

[?11 A No, not real1 

[22i 0 

[?j’ A 

Is It a book &at you own? 

[?4j 

I read it. I dont ’ htnk I have it any more. 

Q All ri ht. I next want to ask you about anything 

[zj! you know about a ? alentrnes ’ Day ad - 

[I! 

t y”“. that Ms. Lewinsky may have placed in The 

!;! Washinaton Post. .-. 

[4; - A Yes, I do. 

[51 Q What can ou tell us about that? 

A That she dy td place an ad and it was made out to 

i:i Handsome which I guess was her nickname for him or 

1s 1 somethrng,one ‘ of them. And she did place it in The 

[gj Washrngton Post. And she told me that she had told him about 

110 1 it, or showed it to him. I dont ’ know wheh. And he Irked 

[ 111 it very much. 

[12! Q Did she say what year she was talking about, 97 ‘ or 

_ .nc+-l 

,l,, JO.’ 

[I41 A 

115! Q 

Im ’ goin to guess 96. ‘

I can hep 9you out. 

Cl.51 A Yes. This IS -wait now. I dont ’ know. 

117! Q 

iiei 

Last year would have been 97. ‘

A Q Ri7ht1 Le me show you a document that we obtained. We 

~~~~will mark this as DF 2. 

!--, (Deposition Exhibit DF 2 was 

[121 marked for identification.) 

[231 BY MR. EMMICK: 

Q This is a two-pa e document that sa 

iit;Fax Transmission, From Debra 8. 

s on the front, 

rnerman, For Mrs. )(narcia Lewis, 

Page 23 

: : ! and there is attached to it a page of Valenhnes ’ Day ads. 

.? 1 You can see at the to it has a date indicated. 

What I wou P d lake you to do is take a look at 

i:jthese. You might want to look at both pages, because I will 

;jjask you some queshons about both. 

;e: Do you reco nue that? 

,y> A Yes. T 8 ats ’ my writrng. Wheres ’ the ad for him? 

isjOh. there it is. Oh. okay. Oh. yeah, okay. Yes, I know 

[ 3 1 what this is 

[13; Q Okay. 

[:I: A Okay. I know what this is 

[I?: Q Do you see on the second page there is an ad there 

[ : 3 I for Handsome? 

::4j A Right. 

r.: ,-21 Q And at the bottom of that ad. it says simply M 

A Right. 

Q Did ou know anythin about that ad going into tne 

aperbefore it wen r. into the paper? 9 

now about the planning of it at all? 

n other words, did you 

[ZOj A I suppose I drd. 

!ZI1 Q 

A 

Okay. In what way? What do you mean? 

[::I 

[r3lad. Yeah. 

I guess Monica told me she was going to place the 

[:4; 0 All right. What about that first page that has Fax 

rzslTransmission and - 

Page 24 

111 A Whats ’ this? 

[?I Q I dont ’ know. Why dont ’ you tell us what that 

t 3 1 means? I think you indicated that that was your handwritin 

f 4 IThere is a reference to “Amount: 5099.00.” Do you know w 3, at 

[ 51 that refers to? 

A No. I dont. ’ I know that I must have - Monica 

!;must have asked me to fax her a copy of this ad, that I had 

; h i it and she hadnt ’ seen it or something. 

[9! Q 

rlolsister? 

And Marcia hadnt ’ seen it? Marcia, being your 

A I dont ’ think Marcia - es. I dont ’ think she was 

I:i 1 there. Well anyway I dont ’ know. I t ave this feeling - 

! :;I well, this is because ‘ it’s ’ Marcias ’ apartment. So. Im ’ not 

r:41sure I faxed it to Marcia. Im ’ sure it was Monica who said, 

i;sjfax A to me. 

!lEj Q All right. 

1171 A And probably because its ’ Marcias ’ apartment. I 

[ 18 Ithink. See I dont ’ remember exactly. 

:19j d What is the reference to 5099? 

!?O! A I have no idea. Really, I seriously dont ’ know. I 

(2 11 dont ’ know. 

122: 0 And as you sit here, are you certain that you were 

;23lsending this to Monica rather than to Marcia, even though it 

j 2 4 1 says for Marua? 

;25: A Hmm. No, Im ’ not certain. Im ’ sorry. Im ’ not. 

Page 25 

i;l Q 

:z!to? 

What fax machines would you have been sending this 

i31 A The Watergate, I think, the office. You have to 

[ 4 1 put the residents name on it. 

Q All right. And at whose request were you sending 

Izithis, as best you can recall? 

[7! A I thought Monica but maybe not, because I dont ’

19 1 know what this is. 

[ : i ; 5099.00? 

Q When you say “this”, you are pointing to the amount 

A 

I:; 1 Unless Marcia may have said, would you check my 

I mean this amount. I don? know what:;; is. 

I;31 though? Wait, let me try to think. This could have been ’ 

114 1 Marcias ’ baQlancte&vy. in her checking account. 

(151 

A Why would Marcia ask me to do that? Im ’ sorry. I 

I:;idont ’ know. Its ’ nothing important to you, Im ’ sure. I 

Page 20 to Page 25 OIC-starr 
Page 26 

1132 

Debra Finerman, 3118198 XuhX(5) 

Page 29 

A Yes. 

It looks like it says 10.29 a.m., and I guess that 

after Valentines ’ Day? 

was 

Page 27 

-: : getting these calls? 

.?1 A I think it was while she was still working there. 

:;(And it mav have continued until after she was at the 

ii i Pentagon: 

-:- Q One of the things that you indicated when we spoke 

j 6 iduring our proffer-interview was that you thought that at 

-: 1 least some of the calls might have been in January or 

is; February of 1997. Is that consstent wrth your recollectton 

: ;: now, or IS it a bit different from your recollechon now? 

-“. A This is after the election, right? 

. . Q The election would have been November of 96 ‘

A Right. I dont ’ think so. 

i‘ 

.:::ofg77 ’

Q You think it was earlier than January and February 

A Yes, I think so. 

.I<: 

_ 5 0 Okay. 

._. ! A Oh, yes, Im ’ sure. 

_. _:, Q Now, do you mean to say that it started earlier 

: 2: than that and - ^.I 

--_ 

. 

--. Aa Yes. - it was - 

--. A Yes. 

0 Can you tell me your best estimate of the time when 

z: j these telephone calls started, or when you first heard of 

: J : them? 

Page 28 

. A I think they started when she still worked there 

iii until a little bit after the Pentagon, she went to the 

: 3 j Pentagon. 

:a: Q All ri ht. 

3: A So. t ?l at would have been 95 ‘ to earl 96. ‘

0 

!lApril ‘ of 96. ‘

Although actually she started at the b entagon in 

:?‘ 

13; 

A Right. 

Q Did she at some point simply stop telling you about 

::: j any phone calls? Or what is the basis for your bracketing 

: : : : the time? .._). --I A Right. I stopped hearing about them. 

3,: 

: t 4. about? 

Q About how many of these phone calls did Monica talk 

.__: .-i, A Five maybe. 

. _. Q What did she say about what the President said 

Is i during those phone calls? 

::3: A Hmm. She didnt ’ tell me. 

Q Did she say anything about who else might be 

-z:jaround? For example - 

-.. A In the White House? 

--1 

..-_ 0 Right. 

'Z3' A No, because I think he was calling her from - one 

:: i time I know he called her from his bedroom. 

5: Q What did Monica say about that? 

11: A Thats ’ all she said. I think when I - that is 

i?lwhen I said, how could that be, how could he call you. from 

[xlwhere, how could he do that. It seemed to me that somebody 

[ 4 Iwould be listenin or his hone calls would be monrtored 

[s~somehow. So, s 8 e said -P hat he called from the bedroom, whrch 

[ 6; I think is in the residence. 

Q Did 

I 

ou dtscuss at all the fact that the 

ii:Presidents ’ wife HI lary Clinton might have been around? 

191 A No. I assumed she was not. 

ii01 Q 

i 11; Monica at all? 

All right. You dont ’ recall drscussrng that wrth 

A Well I dont ’ think. I think I assumed I may 

I::; have said, was - I mean, obviously, she wouldnt ’ be sittrng 

iijithere. No. 

Q All right. What I want to turn to next IS some 

Iizi uestions about the sexual nature of the relationship between 

[ 17 1 8 resident Clinton and Monica Lewinsky. 

[I81 A Okay. 

Q At some point, did you come to believe that the 

jizjrelationship between President Clinton and Monica Lewinsky 

[ 2 I 1 was sexual? 

1223 A At one point she told me about an incident that 

rz3lhappened. 

[241 Q Let me turn right to that incident. 

t251 A Okay. 

Page 30 

Q 

i:; that incident. 

And then we will ask questions on either side of 

[31 A Oka 

141 Q Firs! as best you can, give us the date when this 

is j discussion took lace. _ 

A l-&m. Well all I know is that I think it was when 

Itishe was working there. So, I would 

8 

uess its ’ in the winter 

!a 1 of 95. ‘ I cant ’ say exactly. Or it coul have been January 

tgi96. ’ It would be rn that timeframe. I think. 

[lOI 0 

i I 11 discussion? 

Where were the two of you when you had this 

Ii21 A We were at Starbucks ’ on Connecticut Avenue. 

[13! 0 Just the two of you? 

(141 A Yes. 

1151 Q Tell us what the two of you talked about on that 

i I6 j subject. 

A Well she had been telling me that she went to 

i:iivisit the President sometimes. or when she was workin there 

(19jshe would go into the Oval Office sometimes. And I di 8, n t 

lzolknow what, you know, what for, what, did they have 

[: 11 discussions or was it work-related. 

iI?, And then this oarticular time she told me about an 

ijijincident where she said that he - I guess 

(2 4 1 somehow gettin 

jzs jodd. And so, w t? Y. 

ph sical. And she said 

en said, what, she said 

Page 31 

111. 

Q All right. Can you 

I: i this came up? For example, did 

ive us more context as to how 

s 3, e say why she was there? 

A Hmm. Honestly, I dont ’ remember an 

I: 1 part, because it was sort of strange. And she also, t I?’ 

hrng but that 

[ 6! she said it was, she said, Debbie,, I have to tell you 

e way 

t7lsomethin so weird. And so I said, what. And she told me 

i 8 1 that. An B I didnt ’ ask any more questions, because that was 

i 91 kind of, that was weird. 

0 Right. When ou were describing it just now, I 

I:!ithought you said something II (( ‘

[ ~rlsomething sexual? 

e they were involved in 

1131 A Physical. 

[I41 0 Physical. 

[I51 A Yeah, somethin physical. 

Q Can you remem % er what her words were when she 

1:76jdescribed that? Did she use the words “foolin around”, or 

[ 18 ldid she use some other way of describing wha 9 they were 

[lsldoing? 

A Foolin 

15:; honestly remember. k 

around? Maybe. Im ’ sorry. I dont ’

he could have said that. Maybe she said 

t22lfooling around. 

1231 Q 

L-241 A 

But you dont ’ remember what her words her? 

She didnt ’ say that to me. I dont ’ remember that. 

c:51 0 The idea that was conveyed to you was, what? 

_ 

oicstarr Page 26 to Page 31 
BSA 

Page 32 

Debra Finerman, 3/l 8198 

-~ 

A Oh. well. I do remember that I said in the Oval 

! i 1 Office? And she sard. no In this little office next to the 

;;iOval Office. I think I told vou at the interview where I was 

1133 

XMAX/SI 

1; very ‘ sur rised that anythrng that personal could be oin on 

ijiwith all t! o s e windows And then she told me, no, I .$ s o B 

t f I this little office. 

And until recent1 I didnt ’ quite understand where 

:i ;the sink was, but apparent r* ytheres ’ a bathroom. Right? Off 

i g~that little office. So. I sup 

8 

ose thats ’ where it was. 

;15: Q All right.. ut thats ’ not,based on anything you 

,:: 1 learned fr0fAr-r heGodunng thts conversatron? 

,;*, L -- 

[13: Q Thats ’ - 

:i4: 

[lj; Aa R'ght. - reconstructing it - 

iI61 

Aa y: ’“ wrth recent news. All ri 

I :i i reaction when she described this 9 

ht. 

inciden ? 

And what was your 

I191 A Well. not shock, but kind of dismay, or negative. a 

f 20 1 negative reaction. 

i21; Q And did you express that to her? 

:zz1 A Yes. I did. 

Q Now. nor to this discussion with her, had you 

if:icome to believe that P here was possibly or probably a sexual 

;~srrelationship between the two of them? 

Page 33 

;:-i. 

A 

[ 5 j Involved? 

Q 

Well, I knew that there was kissing involved. 

Okay. How do you know that there was kissing 

[4I A She told me. 

[51 Q 

[ E 1 involved? 

Okay. What did she say about there being kissing 

A She -well see I have to be careful. I dont ’

Ii; know whether I remember this or ‘ I think I remember it. She 

(9) must have said, oh, he kissed me: or, hes ’ a good kissel; or 

i ~o~something like that. And I dont ’ remember exactly, but I m 

1 II Ijust thinkrn 

3 

I must have known somehow. 

ilZl 

;:3lthis with YOU? 

Was anyone else present while she was discussing 

(i41 A No. 

Q And what is your reaction when she says that the 

i i 2: President is kissing her, or IS a good kisser, or words to 

i 17 1 that effect? 

.~~. IIC] __ A Bv then, I understood that there is something _- going - 

1?9lon here. 

Q Now, would her descriptions of kissing the 

ii? i President would that have been before or after lets call 

i:z j this, the &nk incident or the sink discussion? Would that 

: 2 3 1 have beenAbefore? 

iZ4! 

i251 Q ~?~~~%nt%!ember? 

____ 

Page 34 

You just dont ’ know? 

A (Wrtness shook her head indicating a negative 

ilsjresponse.) 

0 How many times did you and Monica discuss the 

I::l]subject of the President kissing her? 

Cl81 A Maybe three times. I dont ’ know. 

[I91 Q That sounds to me like its ’ an estimate? 

[Zi)] A I mean. I - right. I had an idea that something 

;:llwas going on here. Yeah. 

Q And the discussions about him kissing her, was that 

i&ipart of theLasi;tsr what you concluded? 

:24: 

1251 Q Can you give us any more detail at all about what 

Page 35 

:: Monca said about the President and her kissing one another7 

.- A No. I think thats ’ it. Except I think when she 

: 3 -told me about the sink thing, she probably thought that I 

: 1: would want to hear more details. But when I showed that it 

: I .was something I didnt ’ want to talk about. that was it. Then 

: ..she sort of clammed up. 

._. Q Right. Other than describing the kissing 

i I. incidents, and describing the sink rncrdent. were there any 

: 5. other dLscussions of any physical contact with the Presrdent? 

:,.. 

,--_ A No. Not that I remember. 

,. Q All right. Were there any discussions between the 

~~~:hvo of you about an 

; :;-them in some sort o 

times when others came close to catching 

i:: A but I know she told me 

: : 5 ’ tha! Nel. who is a stewar or a butler, either knew or 

; : c -somehow was a confidante of hers. I dont ’ know whether he 

[ : - : actually saw or he sort of figured out. Or somehow he knew 

:: 5 : that something was going on between them. 

113‘ Q 

r_-: 

When did you learn about Nel and what Nel knew? 

i?liOne. 

A She showed me some 

And I said, oh, youve ’ been on 1F 

la ing cards from Air Force 

rr orce One? And she 

[-:.-said no Nel ot them for me. And so. of course I said 

r:::whos ’ Net I &ought it was a woman. She said, its ’ - she 

j: a i explained who he was, and thats ’ her friend. 

c25: Q When would that conversation have taken place, 

Page 36 

r 1: while she was at the White House, or would it have been 

;z:sometime while she was at the Pentagon? 

.;‘ L-. A 

Q 

Ill ’ guess the Pentagon. I dont ’ know exactly. 

;;‘ 

;s:the Pentagon? 

Can you pick the time any more accurately than at 

re“g7? 

Would it, for example, have been in 96 ‘ or 

,_: A Hmm. Oh, boy. I really dont ’ know. Im ’ sorry. I 

r::cant. ’

Q Based on your conversations with Monica, can you 

[ ii:tell us who else Monica may have told about her physical 

I: 1: relationship with the President? 

1::’ 

[I?: 

A Linda Trip 

Q All rioht. Al nd what did she sav about what she had 

,ic:told to LindaTri ?” 

:=. ‘ A 

i z i! Pentagon, 

&I when she first started working at the 

she had met ‘ Linda Tripp who, I guess, worked there, 

1: - : too, somewhere nearby. And she told me she had met this 

;: s .woman. And over the course of a few months,, she mentioned 

;:?: her and she said some strange thin 

;::: I didnt ’ understand why they would 

s about this woman, which 

!e friends with each 

:: : : other. She was much older. She had children almost Monicas ’

:zage. 

--2’ And she told Monica that she was a witch and she 

i!i i had psychic Owen. And she told Monica that she had this 

[: t : feeling that B resrdent Clinton felt very special about 

:I : Monica. And Monica, this was different. She told Monica, 

1:: this is different from all the other women hes ’ ever had. He 

! 3: really must be in love with you. 

i:: Q And that is what led you to know that Monica had 

: 5: told Linda about the physical relationship? iq _-, A Yes. _ 

.-. 

i.: Q All right. Who else did Monica tell about the 

;3 physical relationshio with the President? isi. - A I dont ’ know. 

i::: 0 Do you know whether she told Ashle Raines? 

[I;; A No. I dont ’ know how much Ashte 

[:I’ Q 

I:;: 

r(f&nes knows. 

What about with a woman named athleen? 

,--. A Kathleen Willey? 

i::: Q No, another friend of hers. 

t15: A Catherine? 

[ii: 0 Maybe Catherine, Im ’ sorry. 

i:-’ 

[Isi 

A Okay, Catherine. 

Q Yes, Catherine. 

r. i- L-d. A I dont ’ know what she told Catherine. 

i-.-‘ 

.- -. Q Im ’ sorry. I had the pronunciation wrong and the 

~2: .spelling as well. 

[:I: A Im ’ sorry. I dont ’ know what she told her. 

1-7 Q All right. Do you know whether she may have told 

i!;isome friends in LA about the ph sical relationship? 

1:s: A No, but then you i rought somebody from there, 

Page 32 to Page 37 oic-starr 
1134 

Debra Finerman, 3/18/98 XY&I,,\ 

Page 38 

::.Neysa. 

._. 

,- Q R&ht. But Im ’ - 

i;j 

4: ‘

.5’ 

A 

4 

at you knew from Monica. 

I dont ’ know what she told 

i g i anybody. Shes ’ told lots of people. 

._. 0 So. as far as you knew, she had told Linda, and you 

: 2 j knew that Nel k_new? 

2: ‘ A .-, ^, Q !%$ou knew that she had other friends, but you 

1:: jwerent ’ sure whether she had told those friends about the 

: 1:; physical relabonship? 

:I?: A Rght. Well, I was very surprised if s!e did. 

4 : because I think I mentioned to you at the Interview. if we 

i f 3 Iwere out somewhere in public, and I said anything about 

: : 6 j anybody at the White House, shed ’ say,. shh. don t talk about 

: : 7 1 that. Not even anything to do with President Clinton. So, 

; : 9 1 it seemed like she was so discreet. Thats ’ why i dont ’

: : 3 1 understand this. This is bizarre. 

Q Dii she say anything about how the meetings with 

[ii j the President were arranged? For example, what times or what 

: 2: 1 days they were arranged. ,-2. A She would sa 

i I: j Thats ’ what she would say. SO. 

things like, I get to go there today. 

..- 5. ‘ 1 0 Did she say any particular days that were better 

Page 39 

! 1 :for her to go there? For exam F: le, on a weekend or a 

i I 1 particular day during the week. 

i3; A Yes. I think she said weekends she might get to go 

; 4 ~because there were fewer people around. 

>1 Q 

I6 i said that? 

Ail right. Do you remember approximately when she 

7: ‘ A Hmm. Somewhere in there. I dont ’ know. 

1 

Ii: .*, 

;:3; 

. . .2 

.-I, 

.._. 

.--, 

.:3: 

::4i 

.. =: ,--, 

6’ 

Somewhere, like - 

Q While she was working at the White House, or would 

it have been while she was at the Pentagon? 

A Lets ’ see. Probably while - both, maybe. Both. 

Either whether she was at the White House or at the Pentagon. 

I think she -- you know, if she would ever go there, I think 

it was alwa 

CJ 

s when nobody else was around. 

Did she say anything about how these meetings with 

the President were arranqed? 

A Not to me: 

Page 40 

11: A Yes. 

;2; Q What osition is that? 

[j] ; Secre P ary to the President, I think. 

:a, And -.- what . . -_ do -. vou understand from Monica was the role 

if j that Betty ,a$ have played hthii relationship she had with 

; 2; the President 

A Well, I know that Monica may have said to me 

y 3 i something like, Betty -. Im ’ waiting for Betty to call to see 

f 31 if I can 

[ :o]that. P ? ease dont ’ ask when. I dont ’ remember dates a 

o there. That kind of thing. I remember hearin 

P all. 

I. 1 Q 

~&alls to Betty? 

Did Monica make frequent references to Betty and 

A 

i iT;about Bett 

I think recent1 I dont ’ remember hearing much 

?i 

Cunie except WI .r hm the last few months. 

151 ‘ All riqht. Lets ’ talk then a liile bit about the 

116jconcems that your s?ster had about this. 

;17; You had mentioned earlier that ou had come to 

i 13 j believe that there was a hysical relations K. 

: 13; confirmed fair1 

Jpand that was 

Wha 

y Monicas ’ descn 

P 

bon of the sink 

[~:1 ~incident. about your sisteh reaction o all of !ha? 

.-. 

:,z 1 hated the 

A M 

though r 

sister was very upset about all this and she 

that Monica would be infatuated with this 

:23lman. 

:241 Q Lets ’ try to ick the times and dates of this as 

; 2 5 1 best we can. Again, lets ’ P ecus on the fact that Monica was 

Page 41 

1: 1 an intern from the summer of 95 ‘ until November of 95 ‘ Theiz 1 she worked at the Whrte House dself from November of 95 ‘

13 i until April of 96. ‘

[41 A Okay. 

Q Is there some way that you can describe the 

Iz\evolution, d you will, of Maraas ’ reaction to all of this? 

A Well. this whole thing started retty slowly. In 

iliother words something like wow he keeps P ooklng at me. 

rglblah, blah, &ah. You know,1 ‘ wasn’t ’ there when she talked 

: iolto Marcia. So. I dont ’ know what she told Marcia. 

(111 

[12] A Q Bu Ri?ht. I can tell you from what I knew this thing sort 

:131of snowballed. And it got Marcia sort of neutral, I guess, 

i I 4 I until suddenlv it became obvious this was somethina t=vnnd 

i;;;just an infatuation. ’ And especially when Monica sard, ofher 

r 16 I people at the White House hate me; they are calling me a 

t 17 j stalker. 

And the way Marcia thought of it, as a mother, was 

i :“,i now my daughter is not making any friends. All these people 

i201 hate her because of this thing. And I dont ’ even know if she 

[ 2 i 1 knew if it was physical or not at that point, except there 

[22]was something going on, and it was impacting negatively on 

123lMonica. 

i::lthis? 

Q Did you have discussions with Marcia about all of 

Page 42 

[II A I must have, sure. 

[?I 0 Do you remember discussions of that kind, where 

r3lMarcia was concerned about Monicas ’ situation? 

A Yes. I remember it because I guess Marcia - now, 

Iz;this is just my guess, but I think its ’ true. Monica - I 

[61dont ’ know how much she confided in Marcia about what was 

on. But Marcia 

:zithe sink incident there was pretty obvious confirmation that 

17 Ithere was a 

_lslto Marcia? 

h &al relationship. Did you convey that idea 

1191 

At!&fy~~ tell Marcia what you knew? 

[201 Q Wh not? What was your thinking on that? 

i?ll A We x. , It seemed to me if Monica wanted _ Marcia ._._._. - to ._ 

122 j know what was goin 

l__,.-- , 9 

on, Monica would tell her. I didnt ’

F 7 3 I reallv think I wanted o oet into that with her. 

But Im ’ not s& - you said that I confirmed there 

i:liwas a physical relationship? No. 

Page 43 

Cl1 Q Okay. I dont- ’

(21 A I didnt ’ do that. 

Q All right_ You came to have a 

I :I that there was some sort of ph sical 

reater assurance 

relations $- up as a result 

15 1 of that. 5 Is that a fair statement. 

[Cl A As a resuit of her saying that there was kissina 

[ 7 1 going on. 

I89ifirst thin 

0 All right. So, the kissing would have been the 

that led 

1101 relations R. ip. Wou Y d the fooling around and the sink incident 

ou to think that there was a physical 

I .--, I I I be a further confirmation? 

[I:1 A Well, es, I suppose. 

Q All rig&. Did you try in any wa 

I::;Marcia the significance of the relationship. or x 

to convey to 

e nature of 

[ lslthe relationship, between Monica and the President? 

A Let me try to think whether I actually told her 

I :7”; what Monica was doing. No, I dont ’ think I told her. 

Q Did you by to convey to her something about what 

~:~~you knew, since Marcia is her mother, Monicas ’ mother? 

~~~iimportant. 

A Hmm. Im ’ trying to remember, because this is 

I think we had general discussions about it. But 

[22 j I dont ’ remember if I was kind of a snitch and told her what 

[ 23 1 went on, or assumed she knew. I dont ’ know. 

1241 Q Do you think she already knew? 

I251 A She knew something was going on, but I dont ’ know 

_____-. .______~ 

olcstarr 

__ .___ 

Page 38 to Page 43 
1135 

PC& Deba Finerman, 3/18/98 XMAXle., 

Page 44 

; :. if she knew details. .^ Q Dtd she ever ask you if Monica had confided in you 

I< : more details than Monica had confided in Marcia? 

A I remember Marcia saying Monica is very upset. 

If would ‘ you please find out whats ’ goin 

i;ifrom work and shes ’ in a bad mood, P, 

on. She comes home 

s e wont ’ talk to me. 

: - : What is going on? 

:S: Q All ri ht. 

; 2 A So. t z ats ’ when I went out with Monica and I would 

:f ;. try to find out whats ’ happenin with her. 

(1:: Q And when you 3 ound out, and Marcia had asked you to 

[ :z : find out, did you tell her? 

CT’ A Somewhat. 

:: 

,z no I Okay. didnt ’ tell her details --_ 

a 

-.-.. _ _-. 

Z ‘ What Im ’ trying to get at is, when you say you told 

f-i her somewhat, Im ’ trying to fi 

:P: A No, Im ’ sorry. 9 dont ’ remem 

ure out what ou did tell her. 

h r exactly. I know 

~$.that we both had an idea somethings going on with this guy 

2 5: and I just dont ’ really remember havrng conversatrons. 

71 ’ .tellina her whatever it was I said. I know we, in general, 

i I_ : kneisomethin was hap ening. 

~~~~about it? 

Q wlj right. 8. Id you tell Monicas ’ father anything 

I451 A No. I dont ’ talk to him. 

_ 

Page 45 

i. : Q All right. When you sa 

;t: somewhat what you had learned from Monica to Marcia when did 

that you tried to convey 

to conve that? Would that have been while Monica 

~~~~t~ll at the & hate House? Or would it have been sometime 

1:: after you learned of the kissing incidents,,or would it have 

(5. been sometime after you learned of the stnk madent? 

[-. A Hmm. Boy. I dont ’ remember haven - I cannot 

i 5 : recall anvthina. havino actual discussions with her a % out 

i s j that. I dont ’ k?iow. - 

[X’ Q All right. You mentioned that at some point Monica 

f 1: : expressed;oncehm;ua$out being labeled a stalker? 

[II 

[13: Q I assume that happened sometime while she was 

:: 4. working at the White House? 

[T_. 

,--. A 

I;E Q 

i : 7 / unfair? 

!$“&re ever say anything about that label being 

i-i- &l-. A Yes. 

!?; Q 

[z-: 

What did she say about that? 

A Okay. I think in relation to - all I remember is 

I::. an incident, like where she said the President called me at 

:- -. m office and this sounds really immature, but the wa 

;i_:toYd it is he said If you walk down a certain hallway, 

she 

I’ 7 I

/ :: 4 : look out the window and wave at you. And then she said, and 

1::. I got in trouble from Evelyn Lieberman. Evelyn Lieberman 

_ 

Page 46 

i : : said I wasnt ’ su 

[z- And t i 

posed to be there. 

en 

: 2: stalker. 

she said, so,. now they call me the 

They say that I keep gorng places I shouldnt ’ be, 

[ 4 : when Im ’ invrted. 

(5: Q And what was unfair about that in her mind? 

1’ 1 sa 

A That she was invited to o there but she couldnt ’

r 

so, because she wanted to protect 9 he President. So, she 

: 9 :go a bad reputation, even though she was invited to come 

:fhere. 

Q 

f President? 

Did she say why she felt she had to protect the 

A Well, she didnt ’ say, but I guess you, sort of you 

: intuit that she has to make sure that nobodv says hes ’ asked 

ianintern to come by and see him. 

_ _ 

Q Monica left the White House in April of 1996. Do 

you ‘ remember having an conversations with Monica about why 

i she was asked to leave t f! 

A 

e White House? 

Yes. Now, wart. I dont ’ know that this - it 

,wasn ‘ t ’ necessarily a conversation. But I think, I understood 

Ithat Evelyn Lieberman or somebody named Trmmy told her that 

the ‘

an ‘ d 

were disbanding her office, and her immedrate supervisor 

she - I think the immediate supervisor was retiring or 

isomething, and she would be transferred to the Pentagon., 

And, Im ’ sorry, I dont ’ remember whether she said 

ithis or I thought to myself that they are just trying to get 

_ 

Page 44 to Page 49 

Page 47 

[I! her out of the wa . or get rid of her, because I guess people 

[z !were noticing tha r they were - you know. 

So. Im ’ trying to remember. I dont ’ think she 

/z i thou ht that they were t 

[jjrnay %l ave deduced rt. I 7 

ing to get rid of her. I thank I 

on t know. 

161 Q Did you mention to her what ou thought7 

!?I A I dont ’ know. Im ’ not sure. Maybe. I could have. 

I R II dont ’ know 

L-,- -- -- --- 

Q Did Monica describe 

[ iij had with the Presrdent. after she had 

1 I1; having to do with their relationship an 

[ 12 Iwhether the President had to be oood for awhrle. 

[13: A I think so. I believe - now, I dont ’ know. I 

i 14 iremember a discussion where she said she went there. 

:15; “went there”. went to the White House 

:?6j A Q Went Whenyousz to the hate House. And I think she said that 

[ 17 1 he told her that there isnt ’ going to be any more,physical 

[la 1 relationship, that he has to be 

(19 1 thing or somebody politically to 3 d hrm that this had to - he 

ood, erther a religious 

(zolshouldnt ’ be fooling around. 

Thats ’ what 

i::ithere, it wasnt ’ always 9 

ave me the idea that when she went 

or some physical thing. I think 

[23]they had a friendship. So, I cant ’ real1 tell you how man 

t25lthats ’ where the ambig& is. They rilly had a friendshi. 

[24 ltimes there was anythin physical tha happened. And I hink 

_ 

Page 48 

ill He told her all kinds of very personal thin 

8 

s about 

12 1 himself. his childhood and his abusive stepfather. o. I 

I L_,--. 7 1 dont ’ know. 

_ -Q Well ’ turn to that in just a moment. This 

I: i discussion that you are describing where Monica said 

r~lsomething about meetin 

t~:saying something about ?l 

with the President, and the President 

I 9 1 whatever reasons, do 

avrng to be good for awhile, for 

r 

ou remember what the time of that was 

i 91 approximately, as bes you cm7 _.. rioj ” 

[ll>in 

,_,,__,A_,- $elieve-it was in the summer before the election 

,881 I.““T,1I”CI_ vy, 

I I rust have a feelir 

Im ’ gorn 

ig ii was 3 

to say July. I don t know why. 

!12. . 

Q All n ht. 

uly. 

I ::i things Montca said t a at the President had confided in her? 

Can you tell us what sort of personal 

r~s]You startei to s eak of somp -lL-- ’

116‘ s,,. riaht. It 

J or mem. 

hink it was very touchin I think 

i 17 j at that time she said that - oh, I dont ’ know if it was 9 hat 

[ 1s 1 trme or another time. These are little snippets of 

i 1 Q Iconversation I remember. 

_ 

Page 49 

A They were similar because her parents divorced at a 

I: j certain age that was traumatic for her. And ma 

z 

be she had an 

131 unhappy adolescence and he did, too. I think t 

[ 4 1 been part of it. 

at may have 

Q Did the President say anythin to Monica about 

Iz 1 whether Monica might be able to come back 9 o the White House? 

A Uh-huh. 

What did Monica tell you the President had told 

I? 7 I come back there. ,--. 

(241 Q As best you can recall, when did she tell you about 

[ :S 1 those conversations? 

___- 

OlCStarr 

!7 
BSA 

1136 

Debra Finerman. 3/18198 

Page 50 

A Okav. I can only say that if she started workinq 

Page 53 

2 j there in April? _ 

_ _ 

3i Q April of 96. ‘ The election would have been 

6 I November of 96. ‘

A After the election. She, she may have started 

ziasking him In the fall of 96. ‘ I dont ’ know whether she told 

7 ime this or I surmrsed after the election ma 

j ! Evel 

be, people like 

n Laberman who were worried abou ty 

?!wou ly dnt ’ mmd if she came back. 

hrs reputation maybe 

olsurmised that. 

I think I probably just 

ill! Q All right. 

, _I ,.-! A I don t think she ever said that. 

:1x‘ Q Well, what would have been the basis for your 

: id j surmising; then? 

i151 Because it seemed to me Evelyn Lieberman and 

16 1 whoever worked with her had arranged for her to be 

j:7ltransferred out. 

Q 

1 iii Monica tell 

All right. After the election then, what did 

ou about any efforts to try to get her back to 

[ZoltheWhite Hy ouse? 

!zii- once in twhile or maybe once she mentioned that she had 

Right. I think once in a while she would bring up 

;s;;either called or one to see the Piesident and asked if she 

124 Icould come ba & And he indicated that he would see if 

[sslanything was available. And this went on like sort of month 

Page 51 

[ I 1 after month. 

And then somehow I know she went and talked to 

;?3isomeone named Marsha Scott. And Marsha Scott apparently told 

I 4 1 her there were no positions. Then Linda Tri 

15 1 her to have an interview with somebody at t f: 

p arranged for 

e Whrte House for 

: 5 1 a position. but she wasnt ’ chosen. 

171 So. I know there was some effort on her part to try 

i P 1 to get back there. 

i3’ Q Let me go back a bit and ask questions about a 

~~;fellow named Walter Kaye. 

111 

1; ’

A Okay. 

13; 

Q 

A 

Fis~u know Walter Kaye? 

14: 

: 

How Ion have you known him? 

151 About 1 3 

0 

years. 

1.61 

17! A 

;zr are fnends with Walter Kaye? 

7‘ ‘ 0 

T i; internshro? 

Did Walter Kaye play any role in getting Monica the 

,- 

I,,., 

( _ i , A ‘ Yes. 

11‘ ‘ _- Q What was the nature of the role he 

,^_: A 

layed? 

Well, my family has known Walter l? aye for a long, 

i_long ‘ time. My sister knows him. My husband knows him. I 

:~4know ’ him. And in the -when we moved here in the summer of 

::5:94. ‘ his grandson was an intern at the White House. 

Page 52 Page 55 

!I: So, when it was time for Monica to move here - 

~~;well. actually, I dont ’ - it must have been in May maybe or 

[ 3 1 March. whenever you apply for an internship, we thou ht it 

~4 !would be nice if Monica could 

.3, 

et an internship at the !Vhrte 

15 IHouse when she was done wrt 

16; Q Right. 

college in the summer of 95. ‘

A So, one of us I dont ’ remember who m 

/i;sister. brought up the possibility to him. And I guess s b 

setf or my 

e 

1 q;filed out applications and whatever had to be done. And 

I 3 j somehow he 

I 11 something to E 

ut in a good word or he wrote a letter or did 

her be chosen to be an intern. 

121 Q 

elp 

Walter Kaye is friends with the President? 

1131 A Yes. 

i141 0 Is he1151 A Well, hes ’ a big contributor. 

!I61 Q Big contributor? 

[I‘ Q I thou 

; T ; wanted to be invited P 

ht he threw a party in early 97 ‘ that Monica 

o. 

i-: ‘

:4: 

IS’ 

A 

0 

Oh, that. Right. Oh. okay. 

Why dont ’ you tell us about that as best you can? 

A Okav. I dont ’ think he threw it. It was actuallv. 

i 6 j I believe it was some kind of a fundraiser or something at s 

: 7 : the Waldorf Hotel in New York, which I think he atways bought 

! s : jots of tickets to. And he would invite Ann McCoy and pay 

: s:for the hotel room,, and Debbie Schfi. And hed ’ just do thus 

[ I o : in exchan e for hrs 

w 

access to the white House. 

nd since he bought a whole table, I think Monica 

i:iiwanted to go. And so she asked me if, when I saw him, could 

[ 13: I just mention it, because shed ’ be one of the many who gets 

11: : to go. So, when I asked him if she could, he said something 

[ 15: Itke. wei!, dont ’ you think your niece is berng kind of 

[ I 6: aggressrve with the President. 

[I-: And that really made me mad. And I said, what do 

ou mean, who says that? And he mentioned that people at the ;;;;Wh de House, Ann McCoy,,Debbie Schiff, had been saying that 

r?::she was hanging around him and blah, blah, blah. 

i17j 

IlB! 

A Y&s. 

Q & he also friends with Hillary Clinton? 

I191 A Yes. 

I?01 Q Which of the two is he better friends with? 

i?ll A I think Hillary Clinton. 

i?;! Q Have you ever discussed with Walter Kaye the fact 

I? 7 I that President Clinton is a flirtatious sort of a fellow? 

A Yes. 

0 What sort of discussions have you had with Mr. Kaye 

r : on that subject? 

. A Well, I remember different snr oets of 

j-conversations, ‘ and I remember that he woul s 

.: ‘ -somehow - well, Im ’ tryin 

say - we would, 

to remember how Either I told 

: 5 -him or somehow he alrea % 

: c -were getting very friend1 

y knew that Monica and the President 

\ 

And I think it may have been 

.-. that he heard gossip at t e White House from Debbie Schiff 

: I -and Ann McCoy and maybe even Evelyn Lieberman. I dont ’ knew 

: ; because he knew all those people. 

._: 

--. Either he asked me or I brought it up And then I 

1:. said something like, I cant ’ believe this: this IS 

:: unbelievable. She goes to visit him and theyre ’ getting very 

::.fnendly And he said somethm 

:4 :whew. you should see the way 4 

like, oh, that guy, he, 

e looks at women, oh, boy. 

;- ‘__ So, yeah, I think he had the feekng that - yeah. 

1’ Q Did he ever express an interest in tying to 

.:- f protect the President from his own flirtatious nature. 

[1!. A No, I dont ’ think so. 

[1+- Q All right. You mentroned that Walter Kaye was 

I; r. friends with several oeoole there at the White House. ;s:i A Yes.’ ’ 

,__. IL-. Q I think you mentioned Debbie Schiff? 

[zi: A Yes. 

[Z4‘ Q And an Ann McCoy? 

[:j: A (Wiiness nodded indicating an affirmative 

Page 54 

: : : response.) 

c-: Q 

13: A 

What other people do you remember? 

petty Cume,,l m pre? sure. And before she 

i 4. Mt. blame Willrams. I don t think s es there any more. 

i 5 : Everybody. Lisa Caputo. 

r; Q Did he know Marsha Scott? 

All rioht. Let me direct vour attention to a oartv 

is; jthat Walter Kaye thikw. I believe it would have been in ’ . 

[I: :earty 97. ‘ Does that sound ri ht? 

[:5, A I dont ’ know. ?I e threw many parties. 

I told him at that - I dont ’ know if I 

I said well shes ’ invited. 

(24 -Shes ’ not a stalker, shes ’ not hai in around. ‘ And I dont ’

1 :z f know if he believed me or not, bu P? - hats ’ all I recall of 

___ _____ _~~_~ ._ __ 

OlCStarr Page 50 to Page 55 
1137 

__. . 

Page 56 

Debra Finerrnan, 3/18/98 XM&X[lO) 

Page 59 

;A i that conclusion though? 

A No, I dont ’ recall her saying that, but I think I 

/;;got that feeling. 

Q All ri 

izjdifferent subject. alt R 

ht. Let me then turn to a slight1 

ough still related to Monicas ’ e t=! 01% 

i:lto get a job. Vernon Jordan. 

! A Okay. 

:?I Q Do you know who he is? 

!91 A Yes. 

-:!J! Q Do you know hrm personally? 

: : 1 that. 

Q Do you remember saying anything to him like, well, 

Ii j its ’ not just Monica who is being aggressive, that actually 

[ 4 1 President Clinton had made some telephone calls? 

[jl 

[6i 

A Yes, I did. I told htm tha!. Right. 

Q Tell us about that. 

A Okay. I think in the coume of explaining that she 

[a iwasnt ’ - thats ’ ri ht. 

rsjexplaining that s a 

Thank you. In the course of 

e wasnt ’ chasing him. that he called her in 

rio:the middle of the nrght. I did tell him that. Yes. 

[I:; Q When you said that to him, what was his reaction? 

II”: A I thank surprise. I dont ’ know if he believed me 

1 i;i or not, but he was surprised. 

fi4‘ Q 

;ijjall? 

Did he ask you any followup questions about that at 

[16; A I dont ’ think so. I dont ’ know. 

Q The party that you are talkin 

1 :i i it was, fundraiser perhaps, I think you said 9 

about, or whatever 

I was at the 

~ls]Waldorf. 

r:o; A 

i211 Q 

A 

d‘you ’ remember approximately when that occurred? 

1-71 I dont ’ know why, but I think it was in January. 

;;;So, Im ’ going to guess Janua 

[241 Q 

[251 A 

Last yr then?. 

Not t is January, not this recent one. 

A No.~ 

Q Ever met him? 

--I 

.:31 A No. 

:;41 Q Have you ever spoken with him on the phone? 

::jl A No. 

0 When, with respect to Monica Lewinsky, did his name 

ilflfirst come up as best ou can recall? 

:I81 A * About x ovember of 97. ‘

:191 Q In what context did tt come up? 

A I dont ’ know if Marcia told me or Monica told me 

ItyjMaybe Marcia told me. That Vernon Jordan was helping her get 

::>]a job in New York. 

Q When you and Marcia talked about Vernon Jordan, was 

ii:ithere a “dAe nayyatfhat - 

::51 

Page 57 

AQ Right, but in 977 ‘

I dont ’ even know if it was 97 ‘ or 96. ‘ Could have 

;;ibeen 96. ‘

Q When we spoke earlier in the proffer-interview, you 

i zlsaid February of 97. ‘ Im ’ not trying to - 

[6i A Im ’ sorry 

!,3 0 No, Im ’ not trying to put words in your mouth. Im ’

i B !just trying to figure out what your best recollectron IS. 

A Im ’ trying to remember if she was at the Pentagon 

[ ii1 or at the White House still. Wart just a sec. I think I can 

11: lfigure thus out. 

Okay. Maybe it was 97. ‘ It was after the 

~:~ielection. Okay. It was after the election. So, lets ’ say 

(14 1 it was - Im ’ sor I am bad, bad on dates. 

Q 20 you had that conversation with Walter Kaye. 

i :zj How did that turn out? Did Monrca actually get to sit at the 

;l~jtable? 

A I think she went, but I dont ’ think it had an 

i 1:; to do with him. I think someone else invited her. She go r’ 

hrng 

[:z; there somehow. 

[Zil 0 Sometime after that, I thank you mentioned that in 

i 2: :97 ‘ Monica tried to find a job in the White House. 

[23: A Right. 

c24: Q Had an interview with Marsha Scott. 

iT<. ,--, A Yes. 

Page 60 

111 Q 

A 

- Marcia wanted xou - 

We talked about t IS. For some reason, she decided 

it i he would be Gwen. 

!41 Q WhydidISI 

!61 Aa Wh? s Y; e decide to use a code name for Vernon Jordan? 

A t-think as I told you at our interview we always 

ii 1 had the feeling somebody was listening in to her telephone 

i3]callS. 

I101 Q 

r:l]calls? 

Why would someone be listening in to her telephone 

:;?I A Because of the White House, because of - I dont ’

::3lknow. Dont ’ know why. Because I think I told you that 

: 14 1 Walter Kaye told me every phone in Washington is bein 

: 15 1 listened into by somebody, either an Embassy or the N 2 C or 

: ; 6 I somebody. 

!?7! Q Even assuming that people were listening in on the 

.~s;telephone, why would there be a need to have a code name for 

::glanvone? But whv would you need to have a code name _ for ._. 

i50jVemon Jordan? . 

A 

j::;think thats ’ why t et-e are code names fort e Big 

1331 because probably, you know, if someone is listeninzP ou 

I ress because hes ’ an imphortantrrs; Also, I 

i24 Idont ’ want to go around saying President Clinton, Press ent 

:~slClinton, Hillary Clinton. 

had 

Page 58 

Q Had an interview with someone that Linda Tripp 

I: i helped out with? 

[3! A Right. 

id1 Q How did those work out? 

t51 A She did not - she was not offered any jobs. 

[6i Q What was her reaction to that? 

:71 A 

Q 

She was disappointed. 

181 All right. Any stronger reaction than that, or 

1 slsrmply disappointment? 

I101 A No, I dont ’ remember. 

[Ill Q What did it make her feel about the President? 

A 

I ::ltrying. or ma 

Well, I think that she fett that he wasnt ’ really 

(Y 

be 

[ 14 lget back. I 

he was just saying he would try to help her 

on? know. 

1151 Q Is that what she said? 

i16i 

Cl71 

I?81 

[191 

c-101 

[??I 

[221 

123: 

i-4i L 

[25! 

Hmm. 

Because, a ain, we have to focus on not - 

I understan 8 

&u-s1 what you surmised, but - 

-.. 

-what you recall her sa ing. 

I dont ’ recall her saying x ose words, no. 

All right. 

Or maybe I thought that. 

Do you recall her saying something that led you to 

Page 61 

Q At least though in the circumstance of President 

ii 1 Clinton there is something inappropriate about their having 

13 J a phy&al~latioinsh;;p. 

!41 

0 

izi Jordan was doin 

W% there anqhing inappropriate about what Vernon 

for Monica. 

A f&ybe. I dont ’ know. Maybe that was the 

iii motivation. I dont ’ know. 

0 What did Marcia say about this code name, as best 

i:Z;vou can recall? Try and reconstruct that conversation, if 

:i~jyou would. - 

[121 A Lets ’ call him Gwen. 

:131 Q Why Gwen? 

A Because there is an actress or a dancer named Gwen 

i:45iVemon. Our family is ust ‘ weird. 

!161 Q All righ 1 And when she said, let% call him Gwen, 

! 17 1 what was your reactron? 

t! er 

Page 56 to Page 61 OlCShrr 
1138 

Page 62 

Debra Finerman, 3118198 XMAXIIII 

Page 65 

r.. 

.- A Well. unless you do, no. I dont ’ know. 

_. Cl Well ’ ask rt in two wa s. 

lj: using any code names for anyone w K 

One is, do you remember 

en you talked wrth Monrca? 

..:- 

_1. A 

-2 

Could be. Mavbe. 

iir 

_-. Who do you hive in mind? 

.F‘ I dont ’ know, whatever he wrote there. I oont ’

j i ; know. Really, honest1 

Yv 

I dont ’ remember. 

I-. Q 

A 

All righ 

2‘ ‘ Im ’ sor 

X 

There could be. Yeah, people at the 

:i_iWhite House ma be. h. I know. Ann McCoy. 

1::: Q Ai right. 

,.^. i--_ A ShewasBi Red. 

1.7. Q She was w z at? Bio Red? ,*-. 

[:4‘ A 

::j: Q name for Betty Curie? 

il6: A 

:>_). a When you spoke with Marcia, were there any code 

: 15 inames, otFr than the code name For Vernon Jordan? 

,,j. ‘

1-d. I dont ’ think so. I don t know. 

0 When you spoke with Monica about Vernon Jordan, did 

! t y i vou use the same Gwen code name that you had settled upon 

issj&jh Marci:? 

;;:I 

I dont ’ think so. I dont ’ believe so. 

Q Do ou know whether, when Marcia and Monica spoke 

[2s]wdh one another, t z ey used Gwen? 

Page 63 

:- 1 .-. 

12: lj; 

[ 4 i 

(j! 

; s;dont ’ thinkte discussed it all that much, as Far as I 

!7!recall. 

!8. Q 

: 3 : telephone? 

Did you use that name only when you were on the 

::3: A Probably, yeah. I think so. Or maybe just For 

r:::Fun. I dont ’ know. ,.^. Q Lets ’ talk about the role that Vernon Jordan played 

1:; j in helping Monica find a job. 

;::: A Okay. 

.,:i 

_--, 0 What did ou know about that from Monica? 

I-F- A Well, I di dy n ’ t talk to her all that much dunng 

f f:this ’ time period. Soi all I know is that I did hear that he 

= I- she went to see him. I guess thats ’ the first I heard of 

:’ iz it where she said something like, what should she wear to go 

:I I :see Vernon Jordan. Maybe Marcia told me or Momca I dont ’

1: 1 i remember. 

,7-. s--. Q Okay. 

;:3: A And then my reaction was, Vernon Jordan? What does 

:24. he have to do with this? And then I remembered that he was 

r-5: President Clintons ’ friend. And somebody must have explained 

Page 64 Page 67 

i; 1 to me, either Marcia, probably Marcia or Monica, I dont ’

[ 2 : really know. Somehow it turned out he was going to help her 

r 3; aet a iob in New York. ..,” . 

:4: Q All right. 

7‘ ‘ A But I didnt ’ know whv. I didnt ’ know how, or what 

j 5 i the connection was. 

_ 

Q Did Monica describe any meetings with Vernon 

(11 A 

Q 

I mean, ,I know now, but I didnt ’ know then. 

Let me Identify some occurrences and some dates, 

Iiiand you can tell me what you remember about those dates or 

~4 1 those occurrences. 

151 At yorne point, I believe its ’ on December 5th, 

[ 6 11997, Monrz-a s;;r surfaced on a wrtness kst. 

[71 

[81 Q Do you remember Monica saying anything about bein 

[ 91 on a witness list or possibly being a wdness I? a case? 

A No. I did have knowledge dunng December that 

i iy i something was 

1 :z 1 told you before P, 

oing on. And if it was witness, I think I 

drdnt ’ understand how she could be a 

[13]witness when she wasnt ’ there, she hadnt ’ seen It. And then 

L 14 1 now I understand that “witness” doesnt ’ mean ou saw 

rlslsomething. It means you come and gNe your r estimony. 

r~s]Right? 

r171 

[iSI 2 !??dont ’ think I was very clear on that. 

Q On’ December 19th, she was served with a subpoena 

I:ijDo you remember there being any discussion about being served 

[21lwith a subpoena? 

A No I dont ’ know. Maybe, but I dont ’ - it wasnt ’

[::ireally something L I know it sounds amazin now, but it 

[24 Iwasnt ’ real1 

Y 

something that was very impo 4 ant or 

r2slinteresting 0 me 

i 3 i Jordan? 

A I remember she told me that she went to meet him 

,~~~For breakfast, either breakfast or lunch and at his office. 

: : 1; Yeah. I remember that. 

,771 Q And did she tell you what efforts he was taking to 

~~;jtry to find her a job? 

[I.!’ A 

;151 

Not in detail. She didnt ’ go into that. 

Q 

[:6;Jordan? 

Did she tell you how oFten she had met with Vernon 

[;7: A No, but I know that he set up some interviews For 

1 I3 1 her in New York and she went to advertising a encies. one or 

i : 3: two advertisin a encies. and Revlon. I think at was 

[2:: later. First it s 9r? a ed wdh a couple of ad agenctes and she 

ill 

[?I: had to take a test at one of them. So. I remember her 

: z 2 ; describing that. 

:^i: Q One of the things that you said durin the earlier 

; 2; : interview was that Zlonica 

[ 2s~actually got a job yr 

ou had some concern that unbl 

o er. President Cltnton might just, I 

_- 

OlC-StXl 

:: ;think the words ou used were, “might just dump Monica” 

;.., /-_ A &ht 

z- ‘

:-, Q 

:i: A 

W?rat did pu mean by that7 

Well. my t Inking, he was helping her, but not very 

{ 5: much. I mean, he did a few things to try to help her et a 

ri:ob ‘ at the White House, but then nothrng came of It. 

:7! i 

9 

hought maybe hed ’ just get bored of the whole subject and 

13: not help her an more. 

:3: Q bid you talk with Monica about that? 

ilC1 A Possibly. I ma have. 

;?I! Q What drd you t X ink Monica should do because that 

::2!was a possibility that they might just dump her, I guess, in 

,! ;lvour words? 

il5j A I think Vernon Jordan. 

[Z); ’ Q Vernon Jordan. All right. After Vernon Jordan got 

~2 I 1 involved in the whole process of t in to find a job For 

r221Monica. how did Monica react to t x9. at. Did she react 

fz3lpositively or was she excited about the prospect of getting a 

fz4ljob? 

[X51 A I think she was hopeful, but she was also pursuing 

Page 66 

[II her own other jobs differently, you know, on her own, 

[ 2 1 independently. 

[3; 0 Tell us about that. 

t: i places. 

A I think she was thinking about applying to other 

[61 Q What did she tell you on that score? 

A I dont ’ know. I just - I dont ’ know. I just have 

Iii a feeling that she thought shed ’ better - she may have said 

r9lsomethtng like, I better think about where else I can work or 

[ 10 1 what I could do. I dont ’ remember exactly. 

Q All right. Lets turn our attention to some extent 

i :: 1 to mattenTlatgkFthe Paula Jones litigation. 

1131 

[14: Q Did Monica talk to you at all about the Paula Jones 

115; litigation? 

A She didnt ’ talk to me about it. But I think I 

I :t 1 heard little sni pets ma b? From her or - she never told me 

f 13 1 exact1 

*ty 

I thin R 1 

here. 

during t at bme I mentioned before I 

rlglwasn I was in Aspen. 

1201 Q When you sa “during that time”? 

(2:) A Oh, the time t z at she, I guess, got called or 

~22lwhatever it is. She ot a letter or something that she was 

[23linvolved in it. I don r? know. Because Im ’ not really clear 

124 ion what the whole thing was. 

[251 Q All right. 

~_~ ___- 

Page 62 to Page 67 
1139 

Debra Finer-man, 3118198 xMAx1121 

Page 68 

. cl From your discussions either with Marua or with 

;; TMonica. did Vernon Jordan have any connection to what Monica 

i 5 i was doing in the lawsuit? 

A I know that he took her to see a lawyer, wnich was 

i l i in relation to thus. But at the time it just 

if jwasnt ’ all tpt involved in it. 

- well, I just 

, Other than what vou iust described, that 6. taking 

1 B i her to a lawyer.bid Vernon Jordan do anything else for 

r 9 ( Monica In connection with the Paula Jones litigation? ,;i: A I dont ’ know. 

ill; 0 

[il: A 

p’ that you know of? 

(131 0. At some point, did Monica convey to you that she 

! 14: needed to;rgn;eythrng? 

(:5: 

Ii6 Q Tell us about that. 

A She had to - she was going to sign something that, 

[ii j I guess, somehow, I guess it was this - now I know it was 

c~glthrs affidavrt. And I guess that 7 I dont ’ know why she 

rzo!didnt ’ si n it ri ht away or she drdnt ’ - I dont ’ know what 

171 :it is. Bu 9 she z ad to stqn something. But she drdnt ’ sign 

i:siit right there. 

1231 0 

A he office, I guess. I dont ’ know. I guess she 

j::;had time to think about it or something. I dont ’ know. 

Page 69 

Iiito 

Q What is it that you are remembering that she said 

ou about that at the time? I want you to try to separate 

[ 3 1 o x what you know now from the benefit of recent events, and 

[ 4 !what she tgld you at the trme. 

15; I dont ’ know, but I know that, I mean, I know that 

:s:.she had to sign something or she was going to si n sornethmg. 

~7 1 Idont ’ know. At the time, I guess I didnt ’ know w 2 at It 

[sjwas. 

Q 

r::jwould be? 

ill! A 

0 

/izjdo with the - 

Did you know what the purpose of signing this thing 

No. not at the time, I dont ’ think. 

But you did know that signing it had something to 

il4j A Ww -_ __ _ 

I151 0 - Paula Jones Iitigation~! 

I dont ’ even know If I knew that. I knew it was 

ii!isomething that Vernon Jordan wanted her to sign, or that 

;;;;lawyer waied ;gr “i&r. 

129: 

Q 

She was s?lpposed to sign it. 

We have been at this for an hour and a half. Do 

~-->, ~~~;vou want to take a lo-minute break? 

123: A Sure. 

[24: (Whereupon, the deposition was recessed from 444 p.m. 

~25 1 until 500 p.m.) 

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

Page 70 

[II MR. EMMICK: We are back on the record. 

[?I BY MR. EMMICK: 

[31 0 I will remind you again that you are still under 

r41oath. 

!51 A 

Q %?of the things that we wanted to follow up on, 

i76lwe had ust ‘ been talking about Vernon Jordan. One of the 

i B j things t i at you said was that when Vernon Jordans ’ name came 

[ 91 up, you said, what does Vernon Jordan have to do wdh this. 

M question is, what did you mean by “th&? ‘

I :i i Whats ’ theA -7. hrs..;h;; you were qulurcal about - 

- eemon Jordans ’ connection to? 

Page 71 

Q do’ you remember where you were dunng that ttme7 

A In Asoen. L 

:j; Q When did you come back from Aspen? 

!E‘ A 

._: 8 Q 

About January 4th or 5th. somethrng lake that. 

When had 

.a‘ 

.-. A About the 2 4th of December. 

ou left to go to Aspen7 

19: Q Did there come a time in December when Monica spent 

;::some ‘ time with you In the country, or what she calls the 

;:~:country? 

[“’ L , A Maybe. Could be. Yes. 

1 . L-3. Q 

[;i: 

::5: 

; 

Well, what is your recollection on that? 

lok;;w she came and spent one Saturday with me. 

A But 

I it; was December. 

Y dont ’ know - if you say December, then it 

I dont ’ know. 

:13! Q Well, theres ’ a reference in one of the tapes to 

[ 1s; her initially havin 

rzoldeciding to spen 8 

some plans to go to New York, then 

a couple of days with you rn the country. 

121: A Right. 

(221 Q 

iz,lthat. 

I am trying to determine your best recollection of 

A Okay, I - 

ii:iwith me. I think it was a 

es 

g 

she did come and she spent a day 

a&day. Im ’ guessing. But she 

Page 72 

~1 ididntspend ’ the night. She -we -yeah. The country, 

;;;meanmg I have a house In Warrenton, you know. 

0 All right. 

141 A That s all I remember. 

~~;occu*ed? 

Cl What is your best recollection of when that 

[7‘ A I have no idea. If you say December. it was 

[B ; sometime in December. 

[9i Q But I,dont ’ want to be - 

[lC: 

Aa Oh,,1 - grvrn m sorry. 

I:iwant you to give your % 

you words to acce t or not accept. I 

est recollection. Mp hen was the last 

[ 13: trme you saw Monica at Warrenton? 

;:;i A 

Ilsjknow. 

She rarely comes there. I, I dont ’ know. I dont ’

0 Do you remember what if anything, prompted her to 

it,” f come to Warrenton the last time, or this one Saturday day 

i 1 s j that you have in mind? 

Cl91 A 

Q 

Not specifically. Just, I dont ’ know. 

Do ou remember if you talked with Monica about 

~~~~anything in particu Y ar on that day? 

i22: A 

Q 

Im ’ sorry. I dont ’ remember specifically. No. 

Do you remember talking generally about her job 

IGijsituation, or about anything? 

I251 A Maybe. I dont ’ know. I dont ’ remember 

Page 73 

[ 11 specifically. 

Q All right. During January, was that the time that 

/3; ‘ Monica was talking about signrng something? 

141 A I uess. Yes. I guess so. 

151 Q \rghat makes you think that? What is making you 

[ 6 1 remember that? 

[:I 

!9! 

; Juh.tunbecause you said it. I dont ’ know. 

L-1 

[91 ii Okay. 

I :i i 

Q You have to rely on your memory here. So, Im ’

oing to ask you in a different way. You come back from 

r~2&en. 

I131 A Right. 

Q And when do you talk with Monica afler youve ’ come 

i : z i back from Aspen? 

i16j A Hmm. I dont ’ know. I dont ’ know exactly. 

I171 Q 

[ 18 1 several da 

Do you talk with Monica sometime during the.fint 

s after you get back from Aspen? 

!I91 x Ma be. Could be. 

[ZOI Q Is &at somethin 

[ 2: 1 Youve ’ come back to Virginia. 9 

that you would do ordinarily? 

A 

ouve ’ been gone for 10 days. 

Not really, no. I dont ’ think so. Unless - I may 

[:ii have. Im ’ sorry. I dont ’ know. 

0 Did you meet with Monica from the time that you 

i;:icame back from Aspen to the time on January 16th when our 

Page 68 to Page 73 

_.__ 

OlCStan 
1140 

PPa Debra Finerman, 3/18/98 IWX(131 

Page 74 

: : office ‘ approached her? 

i:. A 

Q 

I may have, but I dont ’ remember. 

7 7 Do ou remember having any conversations at all 

1 ;-wrth her during tha r. time penod? 

!5: A This would be from about the 6th to the 16th? 

I< Q The 6th to the 16th, the 10 days. Youve ’ just 

i 2 : gotten back from Aspen and - 

[~‘ A I may have. I could have spoken to her, but I 

[ ::dont ’ remember specifically. 

t:3: Q Did you speak with Marcia Lewis? 

111: A Im ’ sure I did. More likely I talked to her. 

[I:’ Q At some point did you have conversations with 

:: -,.Monica about her iob? .--. 

1::: A I may ’ have. 

[15: Q 

A 

And getting a ob? ‘

[iE. I may have as k ed her. 

r 1 i.may have said, hows ’ it goin 

tf I had talked to her, I 

;;,; Q 

9, is anythrng happenrng. 

r:g:get a job offer? 

At some porn , did you understand that Monica did 

i20:- - A Yes. 

[?I; 0 How do you think you learned that? 

I?21 

[?3: 

t Yyoeu,mean at Revlon? 

~i~itold me. 

A Either she told me or Marcia did. I dont ’ know who 

Page 75 

0 Would it have been a conversation that you had in 

I:; person with one of the two of them, or was it a telephone 

[ 3 jconversation? 

;:; 

A I dont ’ know. 

Q 

16: A 

Were you in Washington or were you in Warrenton? 

I cant ’ remember. I know, of course, obviously 

[ 7 ; someone told me. I dont ’ remember. I dont ’ even know if - 

(4 7mavbe I was in New York. I went to visit Marcia in New York 1.~ 

i 9.at some point 

cici 

Ii I : 2 %?know. I was there on the 16th ,--_ 

[I:: Q Right. 

(13: A Yeah. So, I dont ’ know. Im ’ sorry. 

Q Was it important for you to know about Monicas ’ job 

Ii:ipros$ects? Is that something that would be of interest to 

[?61YOU. 

117; A Yes. 

:?3‘ Q Would Monica be interested in letting you know that 

: .--. I c.she had a iob offer? 

12:‘ A Uh-huh. Im ’ sure she would. 

[Zi: Q But you just dont ’ have any recollection of - 

i2Z’ A Of the date. No. 

[23: Q Im ’ not asking about the date. 

[z~:you had such a conversation sometime,durin 

[25: A Im ’ going to say, yes, I did, bu ? I dont ’ remem 

Page 76 

r~:it. I must have, because somehow I knew. So, somebody totd 

12 1 me. Maybe Monica. Im ’ not trying to be evasive. Theres ’ no 

i 3: reason to. I just dont ’ remember. 

0 Okay. Did you have any conversations with Monica 

~~~during this time period about si 

A ? 

ning an affidavit? 

!6‘ I knew she had o sign something, and I knew that 

~7 jthat would be I uess leasing to Vernon Jordan. 

Q ’ 8kay. &hat ‘ made you think that it would be 

i ij pleasing to Vernon Jordan? 

A I guess she may have said, they want me to sign 

~~~~this thinq. They. and I assume that was Vernon Jordan and 

ilzithc lawyer. _ 

What did you understand that to mean? 

I didnt ’ know it was an affidavit, but I knew it 

i 2 1 i by the name of Carter? 

[Z?; A Ive ’ heard his name. 

[23: 0 Who wanted her to sign it? 

!14: A I think Vernon Jordan. Somehow I knew Vernon 

izs:Jordan wanted her to sign something. 

____ .___ 

OlCStarr 

Page 77 

. I-, Q Oka .^. !-_ A And r think that Frank Carter wrote it up. 

:>- Q Okay. Do you think thats ’ something?ou timed 

: 3 ~from Monica, or something you learned from Marcia. 

!5: A Oh, boy. I dont ’ know. I dont ’ remember u-o told 

[6:me 

I-’ Q Was it your impression that Vernon Jorda- cr 

f 5: whoever else “they” might be, wanted her to sign this qune 

c?-badly? 

_.r_ .-i_ A Yes. I think so. 

:li: Q 

i:?:to sign this? 

Fair to say they are very interested in get?-g her 

!:3: A 

Q 

Yeah, I guess. 

:14: And did vou aet curious about whv thev wc_.d be so 

iiijinterested in this? ’ - 

_ , 

,. A Im ’ sorry. Not really. Because, you know ! iave 

IiSirny own things going on in my life and Im ’ a writer, and I ti 

ils]assignments and my son. So, if I heard this stuff, I, I, - 

[IS+! pow. of course, its ’ very important. But at the time, its 

[zcr+st a Ion senes of thin 

[zlldid this, s 3,. e did that. S P 

s. She went to Marsha Scott. Se 

[:zlblah. blah. 

es ’ trying to get a job. Blah, 

Thats ’ why, now it seems so 

I::jBut at the time, its ’ just another series 

im ortant to all of us 

oft R. 

[251 Q 

rngs. 

Was there any connection in your mind berween her 

Page 78 

111 signing this thin whatever it was - 

I21 A &-huh. 

i3i now you know it was an affidavit - 

[43 

ISI 

i Right. 

16: 

- and her c$tinr job? 

A Yes. I did ink ere was a connection. 

Iii 

Q And what was that connection? 

A I think if she signed this thing that Vernon Jordan 

[siwanted her to sign, then it was sort of he would be happy and 

I 10: he would help her, or be sure she got a job. Thats ’ what I 

i 11 j surmised. 

- . 

[?Zj Q All right. 

Iijl A Nobod said that. But thats ’ what I thought 

114. Q And w fyi at was said to you that made you sonnise 

[ 13 !who wrote up something, and she was 

r~g:think whatever it was, yeah, was sort o B 

oing to sign it, maoe me 

- 

[201 0 Did Monica come to that same conclusion7 

!?l' A I dont ’ know. I dont ’ know. See, I dont ’ remember 

[xiif I said that to her or that I just thought it. 

[z31sad it to her, but I dont ’ know. 

I may have 

iz:iMarcia? 

Q Do you know whether she talked about tha: wrth 

Page 79 

A No I dont ’ know. I dont ’ know how much Marcia 

I:iwas. oh, interested in all this. 

Q Did you ever get a call from Monica while she was 

I: 1 at Vernon jlorda&s?office? 

!5i 

[6j 0 Yes. 

[! ‘ A I dont ’ think so. 

[@: Q Did you ever get a call from Vernon Jordan trying 

1s; to get hold of Monica? 

[lo: A 

Q 

No. Ive ’ never spoken to him. 

Did anyone at Vernon Jordans ’ office try to get 

I if j hold of her by calling your telephone number at the 

[13;Watergate? 

A No. But I think we - I dont ’ know if this is &at 

I::iyou mean, but I think Monica may have stayed there whik I 

[16]w%ft there. She ma have gotten calls there. 

Cl71 Q Staye cr 

A Yes. 

at your apartment? 

(141 

1191 Q 

[co] 

[21; 

$ 

yy would she stay at your apartment rather - 

I II tell you why. 

A 

- than her own? Why? 

[?2: Because theres ’ a mouse in her apartment. There 

[23:were mice in her apartment, which were discovered sometme in 

1~4 ~December under where, under the living room sofa. You can 

[~5: check this with the Watergate. And they had an extermincor 

Page 74 to Page 79 
Page 80 Page 83 

XMAX(14) 

.come and they never caught the mouse. And since that time, 

i. my srster and Monica didnt ’ want to stay there because of the 

.:. mace. And if we werent ’ there. they would stay In my 

3 -apartment. 

._. 

-. Q All right. 

_ 

.:::true, A You can check with them, too. Its ’ absolutely 

- 2 

Q Oka 

On the 6t X 

Let me ask you about a couple phone calls. 

of January, and just for 

_. information that would have been the da 

f i .the affidavit, and I think you mentioned t 

:: jday that you returned? 

--. A Possibl 

-:. Q Possibi. 

__ A I have t at written down somewhere. I dont ’ know. 

; Q There was a phone call from Aiken Gump. which is 

:’ jVernon Jordans ’ law firm, to the phone number 9651456. 

: i: staying at 

K 

our place? 

zi: Yes. Thats ’ possible. Or.its ’ possible - if you 

;s;transfer a phone, you know, call-forwarding. If she was 

Page 81 

:: :staying there and she call-forwarded her phone, I dont ’ know 

:: if ‘ it would be her number on there or mine. I dont ’ know. I 

: 3 f dont ’ know if they do it that way. 

:;. Q Im ’ not sure I know the answer to that either. All 

: 5 j right. 

:5: There is a hone call I wanted to ask ou a 

--.question about. It is g ack In November of 97. ‘ 1 he phone 

1s jcall occurs on November 13th. Its ’ at 7:30 at night. 

3. A Okay. 

.._. 

i 1: i the thin 

Q Monica calls ou at your 540 number. And heres ’

that is interesting a !I out the timing of the call, 

our memory about it. She had entered 

~:;h‘”,dW~i!$rr%~~~~ZO that same evening. 

.: 

.-y 

__ Q And had spent an unknown period of time !here. :_ _ ; A Uh-huh. 

Q And then at 7:30, that is just an hour and 10 

’ minutes later. she talked to you for 11 minutes. 

_. A Okay. _ ^^. Q What I want to ask you is, what was she calling you 

fi jabout, because as interested as she was, in thin s 

- -. President Clinton, .if she calls you rmmedrately % 

related to 

a er a 

Es ‘ 1 meeting with Presrdent Clinton - 

- . -3 ^:’ A0 R_Its gb‘ . ’likely that the subject of President 

Page 82 

.I : Clinton wo;ld hgk;corne up 

_. 

-_ 

3: Q What do you remember about that phone call? 

4. A November 13th. I dont ’ - is there anything - 

5: AQ Again, the date is not - 

6 : - about that that would have been important? Or? 

-. Q 

:?jrecent - 

Well, did you ever get any phone calls in fairly 

: 3 i House? 

A From the White House? She called me from the White 

: 1 : Q No, no, no. She called you from her home. 

.?. 

--. A Oh. So, she - 

13: Q She goes to the White House. 

Ii: A 

- =. __: 0 

goes to the White House and she comes - 

She spends some period - 

1 i ] A - home and calls me. 

1 7 ! Q - of time there, comes home, calls you very 

: z i shortly thereafter. 

:j: A Right. 

Q And it strikes me that if she placed a call like 

ii i that to you there must have been a reason for it. And since _*. ou were one of her confidantes, she would have been free to 

i-ii r ell you whatever it was happened. 

A Could you help me out? 

j! 5 : that time thats ’ important? I dont ’ know. 

Was there something around 

_._.___ ..~ ~_~ 

Page 80 to Page 85 

1:; Q Other than meeting the President at the Whrte 

I - 1 House? 

. 

Hmm. Probably November, December 97, ‘ recentl:,. 

All right. What makes you remember it? About what 

I:: i time of the day was It. for example? 

c51 A It was evening. And I guess I just walked in or 

Page 84 

111 something and she was brushing her. hair and putting on makeup 

[ 2 1 and gettin read to go there and vrsrt. 

1:; ! icember. 

ow you were gone from the 24th to the 6th - 

I51 

I,“; 

AQ -approximately? 

Icil 

LVI 

2 

Q ‘

Z&i; couldnt ’ have been in that time period. 

Dbyou ’ remember whether it was a Friday or a 

r:iiSaturday or a Thursda 

ty 

or a Wednesda ? 

A I think i was a weekni h because she had - she 

1 :i 1 was working. She was still workin 

[ 131 after she had been working. I don 

9 %.c! it was a weeknight 

know when she left the 

[I 4 1 Pentagon or she stopped workrng there sometime. 

I:51 Q Not unttl after Chrrstman 

i16i A 

-. ..; __. .,-_’ 

Okay. So, somehme in December. 

i:iicall at all? 

Q So, you dont ’ remember anything about this phone 

[Isi] A Im ’ sorry. Its ’ nothing - no. Unless there is 

r?olsomething special that you could help me with about it that 

[ 2 i : could have been. 

Q Other than she ust ‘ got back from visiting 1:; iPresident Clinton in the White /-I ouse. which some might regard 

~241as special. 

rlj; <- A No, because she visited him many times. It wasnt. ’

Page 85 

(1 j you know, I dont ’ think so. I mean, by this point, it wasnt ’

I ,_ 7 lanvthinn :_ ..,......= U~IICII~I _..____. nr _. anvthinr ___, . . . ---r*--,lf-- j J .zcLab”lal. 

131 Q Did ;ht&ver ca! you to say that she had recently 

[ 4 1 been with the Presii 

.~. 151 A Reu 

Q No 

I; j with the Presidenttoday ’

Izi! A Oh. I rust 

sntly you mean to this time? 

no. i,mean recently, as in. gosh, I was just 

got back? L-1 Q Juit iot t _ r:i janvthinq like that? 

lack. vesterday I was with the President, 

illi - - A No, she never - not that I remember. Shed ’ never 

rlzjcall me up and say, oh, guess what, blah, blah, blah, blah, 

i 1x1 no. Usual1 

d . . 

it would be in person, as I mentioned before. 

Right You mentioned that ou were In New York 

i ::iwhen Monica called Marcia in order to exp fy am to Marcia that 

[ I 61 people from our office, including me - 

[I71 

I181 Aa Right. were talking with her? 

[I91 A Ri ht. 

1201 Q W#at was Marcias ’ reaction when she got that call7 

I211 A She was shocked and scared. 

[?:I Q 

A 

Did she explain to you what was going on? 

No. I dont ’ think she knew. All she knew was that 

i::iMonica had gone to Penta on Mall, I think, and then now she 

[zs]was at the Ritz Cartton Ho P el with you. And she just, she 

___- 

olcstarr 
1142 

ESA Debra Finerman, 3ll6l96 

Page 66 

.:. knew she Cad to come immediate1 

.^ 

,- 0 

-. A 

g,phy. You decrde (Y to go with her? 

!A’ 

,:. 

,-. 

;i 

i-’ 

:s 

- :j. 

::. ‘

. . .A. I^ 

Q -My? 

A Moral support. And our mother, too. 

Q What do you mean? 

A 

Q 

Our mother was there, too. Marcias ’ ant my mother. 

$av;led down on the tram wrth you? 

i Af?er you got to Union Station - 

Rrght. 

__ 0 - where did vou and vour mother ~03 

- A My mother went with Marcia to theRitz Canton 

ii.Pentagon.&~nd I went to my apartment at the Water a:e. 

. C’ $ *-. Drd you connect u 

iE:speaking w?h Monrca at the Ritz r5 

the factthat the Bi was - 

arlton with what you knew 

:-,to be the relationship between Monica and the Presider? Did 

12 j you think pre was some connection there? 

: 3 Let me remember. Yes. Right. 

-.: -I_ Q 

,::: 

!::: 

2 

What did you think? 

$\\y time, you mean? On the train? 

A Hmm. I dont ’ know. I dont ’ know what it was, but 

ii z j I knew it was something to do with that, and that Linda Tnpp 

125; had been tape-recording her. I knew that. 

Page a7 

!I‘ Q Okay. 

:-. A I think I knew it then. I dont ’ know if I knew it 

i; i then, or now I knew what it was. 

14: Q 

is: A 

That was the n$ht of the 16th. 

iL’ 

cr. 0 

t;;at a Friday. 

--. 

f:: A 

Q 

Friday. 

And on the morning o 

$morning. there is a call placed from 

h. at 9:00 in the 

r;s.believe IS AMonicas ’ number? 

&&which I 

I:“ ?*-_ My srsters. ’ actually, Marcias ’

,__. 

.-. Q 

“: .--. 

li;rcia s. all right. 

,. s-3 

-: ‘

.--. 

i:i 8 %!!!!!!cond number? 

,._ A A Tha?swhere ’ my mother lives. 

;: 4 : that she did. 

I-: /--. Q Okay. 

Page 88 

1 ii where sheAwas 

I dont ’ know if she - at 9 oclock ’ I dont ’ know 

i 5 j didnt ’

at nine in the morning, but I know ’ that she 

stay there. 

0 Let me ask this question delicately. What did your 

i : 1 mother knoAv about all of this? 

iE: 

: - 1 confused. 

Very little. Nothing. Shes ’ very old and 

:j- 

.-. 6: ‘ AQ 

How old is she? 

r;ofknow much. 

Shes ’ 80. She has Alzheimers. ’ So, she doesnt ’

Q Okay. How long did you remain in Washington, D.C. 

I :: i after corni? down with Marcia and your mother? 

il?l I soent the niaht. Im ’ sure. Im ’ trvinq to 

1 :i : remember. I wouTd have to rook at a calendar. Prgbab’ - 

[: 5 j Im ’ sure the next day. I may have gone back to Warren r on on 

rls;Sunday. I think that s when my husband was rn LA. 

[i7: Q Oka 

A And \ e comes back on a Sunday. So, I dont ’ know. 

I ii; Probably - well, I know the next day. 

I201 Q All right. Thats ’ fine. There is a reference on 

1: I 1 one of the tapes to your sister and you going to somethrng 

[::~called an amval ceremony. 

(23; A Hmm. 

1143 Q Do ou know what that is? 

[25! A Yea K Oh, I know what it is, but thats ’ a long 

Page a9 

: time aqo. Yeah 

- 

: 

- AQ lQT;,umping around in time. 

;- Q Tellme ’ what the arrival ceremony was and how you 

z : and your sister came to be there. 

_ A Okay. I thank rt was somethrng to do with the 

. ‘ President of Korea. Right? If thats ’ correct One trme we 

I : stood out in the hundred de ree weather. And I remember 

zwaiting ’ for the President of w orea to come and then he came 

: .out on a balcony and waved And there were lots of other 

-people. And thats ’ all I remember. -_ ^. 0 Was thus an occasion when President Clinton was 

: -there? 

A Yes. 

Q 

A 

Did you meet the President then? 

Not at that trme. but I had met hrm at a different 

thing, once Or lwce. 

Q Did Monica make arrangements for you to be there at 

the arrival ceremony? 

A Yes, she did 

Q 

sense? 

Okay. Was Monica there with the President in any 

A 

Q 

Not really. She was standing with us. 

Did Monica and the President catch each others 

eyes at all, or wave to one another, acknowledge one another? 

XMAX(lS) 

.____ ____~ 

Page 90 

. 

.-, A Not that I recall. Not - no. 

Q There is a note that we found at Monicas ’

ijapartment, and it says “Love, Deb” at the bottom. We will 

.:.mark it DF 3. ::: 

.-_ (Deposrtion Exhibit DF 3 was 

.F‘ 

-, marked for identification.) 

BY MR. EMMICK: 

fzi Q It has two pages. It looks like it ma be a 

: ;:continued note. Why don t you take a look at it an J tell US 

: : : if you reco nize it. 

--. R “Monica was called by” - 

--. Q Tell us what you reco nize it to be. 

- i .--. A - “Betty to come at 9: 3 0 a.m.” 

:::: Q 

- 1 In,Tlr That may be the second page of the note, but take a 

_:. IVVR. 

-; ‘

: I z j Oh. “Mon& was called” - 

“Shell ’ take the plane. We have tickets for you.” 

-: E : and Peter.” All right. 

okay. Just a minute. “Hi, Marsh 

.-i- “Dear Monrca, this is some of your stuff I 

:f~~drycleaned. Ready tomorrow. Love Mom.” 

White ‘ House 9:30 this a.m. Shell ’ take a plane to 

: F I j N.Y. See you at temple. We have tickets.” 

Oka Riaht. 

__( 6 

.--_ 

*a+ a, note written by someone named Deb? 

A NO, mats ‘ me. Yes, I wrote that. 

Page 91 

: 

.-_ Q You wrote it? I_). 

.-‘ A Yes. 

.-,> 

.-. Q Whats ’ it about? 

::: A Okay. This IS about tickets, tern 

T 5: So, it must have been a Jewish holiday. It mus ! 

le, and Peter. 

have been 

i 6: September Se tember 97 ‘ or something. 

-7; d gosh Hashanah? 

:;: 

- 1 A Okay. Right. 

.;. Q The reference there to “Monica was called by Betty 

: i 5 j to come at 9:30 this a.m.” - 

. . . . 

.~~~ __ / A Riaht. 

.._. 

_--. what is that about? 

:13: 2 

: :: : President. 

That Betty told her she could wme and see the 

Cl Okay. And how do you know thats ’ what that refers 

ii z i to? What did you dtscuss with Monica about that, that caused 

::: jyou to write that note? 

--o> 

ilGjplane.” 

A Just to tell her mother, I guess. “Shell ’ take the 

._?. 

.--: Q Well. lets take it a piece at a time. 

.-. . .--: A Okay. .^_I. Q It says, “Monrca was called b 

f?ji9:30 this a.m.” What do you understand tha r 

Betty to wme at 

to mean? 

A To wme to the White House. 

Q And Betty you understand to be a reference to Betty 

Page 66 to Page 91 
1143 

ESA 

.Currie? 

Page 92 

Debra Finerrnan, 3118198 

_~ ~~ 

XMAI. i, ‘

Page 95 

!;i Q 

A 

A-e you sure it was Rosh Hashanah? 

Wiell. one of those two, Yom Kippur or Rosh 

IijHashanah. Thei are wdhln a week. 

14: Q 

;5: A 

do you remember what day of the week it washo. but Im ’ sure thats ’ easy to,, you know - JUS: 

rs!look on a calencar I know thus was now. This was 97. ‘

[Y’ 

[a; 

Q Roht. 

A A:?east thats ’ helpful. maybe. 

15: Q A.! right.. Lets just bypass It then. 

::01 A Im ’ sorry 

[l?i Q Th:s is a handwritten document. It has 12 

; 12: paragraphs and 10 

P 

ages. We will mark it as DF 4. 

[1X; 

11:; 

Deposition Exhibit DF 4 was 

:15i 

marked for identification.) 

BY MR EMMICK: 

Q What we would like to ask 

I:tilook atthe hanownhng on this and tell us I 7 you recognize 

ou to do IS to take a 

1 la j it as Monicas7 ’

[151 A 

actual1 

Hmm. I dont ’ recognize it, but it might be. Its ’

r?olnot 

; 

hanowritin 

121: Right. 9, 

Its ’ prinhng. 

t s more lrke printing. 

[??I 

1231 Q f&l; + knnw 

_.__. - 

.-_ A Q Ri?h. ’

i 4 j Monica go: and she told 

Is his a call that you qot, or is this a call that 

ou about it. -ii A 

ii ; must have 

Well, I di ds ’n t get a call from Betty. So, Monica 

Monica must have told me. Yeah. 

,_: Q 

:_. A 

Why are you writing that note to Marcia? 

I dont ’ know. Where is Monica though? She ‘ ll ’

i i(take the p!ane.” I dont ’ know. I mean, I guess Momca told 

i 1: : me to let her mother know. So, Monica was - I dont ’ know. 

:: : : Im ’ sorry I dont ’ know. 

I.^- 0 When you say there, “Shell ’ take the plane”, it 

i f 3 j suggests Mat perhaps. there IS a famil meeting, or you are 

i:: : gorng to beAmeetrn wrth Marcia and 

r. c x--J 

Q 

Rig&. 

Jeter - 

ii‘‘ and that rather than perhaps Monica going with 

: :j ‘ you. shell ’ catchup with you by taking a plane. Is that - I- ;l$] 

,T_ji A0 Right. -whats ’ ha 

;::> A 

pening? 

j--. I guess so. t? ut where is she. Where is Monica? 

[21: Q Im ’ askin - 

A I know. t3 o. Im ’ trying - I dont ’ understand this 

IisiThis was Rosh Hashanah, lets ’ say, or Yom Kippur, I dont ’

[?d Iknow which one. They were coming, Marcia and Peter were 

i 2 5 1 coming with us. 

Page 93 Page 96 

,.: 

.-, Cl Okay. 

.T. 

.-, A You need tickets. “Shell ’ take the plane.” 

.i‘ _-, Q 

A 

Where were you goin 

Here, Washington He % 

to go to temple? 

i qi Washington, here. 

rew Temple. Here, this is in 

.i; Q Okay. 

._ /I A This was in Washington. 

lj ‘

.-. Q What does “Shell ’ take the plane” refer to then? 

2‘ ’ A 

: i : j Im ’ sorry 

I dont ’ know. Was Monica going to go to New York? 

,... __ Q Ill ’ have to ask you that. I dont ’ know. 

[ll Q All right. 

[21 A No. I wouldnt ’ know. 

Q Farr enough. I want to ask ou a little bit aboi? 

1: j the use ofred&:rds by Monica and by Fx arcia. 

f51 

I61 Q Did !he sh 

A Yes I t x 

are credit cards, do you know? 

ink so. Sometimes Marcia would let hcnica ’

iH;use her credit card’ I think. 

Q So did ‘ Monica have her own credit cards or a. 

i iiithe charges that were made they just went on Marcias ’ card? 

[:I1 A I dont ’ know if Momca has her own. I know she has 

:12]a bank, like an ATM card. I dont ’ know. I dont ’ know. 

ii31 Q 

[ 14 ! regularly u 

There are credit card charges that are made fa ?y 

il5lMarcia an s 

unhl mid-l 997 on the credit cards used by 

Monica. 

I161 A Uh-huh. 

Q The use of those cards then drops off very 

~:~~dramatically. Is there anythin that happened in the middle 

[ 191of 1997 that caused the use o 9 those cards to drop off? 

A When is this? I dont ’ know. When you say the 

[gyimiddle, when would that be? 

[22! Q I dont ’ know which particular month it was, bL? I 

izjlthink it was in the summer. 

!243 A about that. 

[251 Q 

No, I dont ’ know anythin 

Okay. Let me ask you a % out psychiatrists or 

.~~. 

..-, .--! A I dont ’ know. . 

::j: Q Is it possible that you were going to go to temple 

;:;:upinNewYork? 

.--, _^^, <--. I A Ri ht. 

*--, Q 

A 

v\/4at do you remember about that? .^.. I dont ’ know. Well, I dont ’ even know when it was 

j s; j September. October? I know that Betty would call her to come 

Page 94 

1; 1 and visit him. But I dont ’ know this specific day, if it was 

1: 1 anything important or interesting. 

[j: Q All ri ht. 

I41 A Wha P 

!5! Q 

I dont ’ understand is “Shell’” - okay. 

!6i A 

;;yu$d a uestion that you were about to ask? 

- I dont ’ know what this means, “Shell ’

i - 1 take the plane.” _ 

I?! Q Im ’ not sure either 

,;;; 

A Okay. 

Q 

1:: i remind you? 

What about the second half there. Does that help 

1 

i !;;a 

A Monica was called to the White House. “Shell ’ take 

lane to New York. See you at temple. 

; :.I 10 ay. I 

rls]to!heW&e House. I dont ’ know. 

We have tickets.” 

uess she was gotng to go to New York after she went 

[1E! Q Is it possible that the three of you were going to 

[ 1: ,go from temple up to New York? 

1191 

[191 

; Ngokot ’ at all. 

i_Z: A No, &? cause I remember that. My son is here. So, 

(2 11 no. Do we know what da this was, date? 

iZ_) Q x 

I-5: A 

Thats ’ pa of what we are asking you. 

Youareaskin me now. Im ’ so I dont ’ know. 

;I J ; But I 

?I 

uess you could find ou 9 All you have to 7.. o IS find 

(:5;out w en Rosh Hashanah was. 

Page 92 to Page 97 

i24j A 

maybe its ’ more difficult to - 

I couldnt ’ say without more information who WZD 

(:51it, unless its signed. 

Page 97 

[ 11 sychologists or similar that Monica may have used. Do you 

~2 1 R now whether she has ever seen a psychologist or a 

[ 3 1 psychiatrist? 

[41 A Yes, Ido. 

151 Q What can you tell me about that? 

A I know she went to a ps 

I;;time a o. She went to two. She went o two women. bne was 

%. 

r 

chologist in LA a long 

1s 1 Judith In-Nun. B-l-N dash N-U-N, Judith Bin-Nun. And the 

[ 91 second one is somebod whose last name is Kassorla. Shes ’

tloljust surfaced recently. *hats ’ it I think. 

Q 

I iii psychologists? 

What was the purpose of her going to these twJ 

A I think after my sister and her ex-husbands ’

i::jdivorce, Monica was upset. 

t151 Q 

A 

Why did she see two separate psycholo 

i :7”! much younger. 

She went to the first one I think when s w 

ists? 

e was 

[ 18 jlater. 

And then she went to the othe; one a few yea-s 

1191 Q What did she tell you about seeing those 

[ 2 0 1 psychiatrists or 

1211 A gt!$l$:;:. 

[>?I Q You mentioned that they were from Los Angels. 

I231 A Uh-huh. 

1241 0 When did the psychologist/client relationship erd? 

[ 25 1 Imean, was it a one-time thing quite awhile ago? 

_ 

olcstafl 
1144 

esA Debra Finerman. 3/18/98 XMAX(17) 

Page 98 Page 101 

A No. I think it contrnued for awhrle. each one. 

. 

.-_ Q With both? 

A Yes. 

Q One of the articles about Ms. Kassoria makes a 

i i: reference to her being some sort of a sex-related 

-6 : psychologist. 

.-. A I didnt ’ see the article. I dont ’ know. 

::. Q Do you know anything about that, based on what 

’ +: Monica may have fold you? 

.._. A No. No, but I think she mainly went to her to help 

: f ! her ‘ lose weight, because I remember that Dr. Kassorla tried 

::r:to help her lose weight. I thou ht that was the main reason. 

-7‘ ’ Q I see. Were ert 3er of them prescnbrng any sort of 

: : : : medicationAt her? 

,.: 

.-- I dont ’ think so. 

.’ ;’ Q Do you know whether either of them diagnosed her 

f I’ : having anyAsortNOof~mental problems, other than - 

. ‘ :. .--. 

.. 2’ 

--. 

2 

- depression. .^_. 

.--, I don t know. I never heard about it. 

,-. Q Did she ever see a psychiatrist or a psychologist 

::I j by the name of Hill? Does that ring a bell at all? 

-2. ‘

,--. A Not at all. 

-:: ‘ Q Did she ever see a psychologist or anything like 

if 5 ; that at a weight loss clinic? 

.:.or even - .^ 

.- 

.d. 

. . . I) 

; Well, Im ’ sure. 

A 

-further ago than that’ 

I dont ’ know. Im ’ sorry. But then. whenever thus 

is:started. I think. 

i Q Since Januatv 16th? 

as 

-. A No 

.;: 

.-. Q 

I-dont ’ think that long ago. 

February and March? 

i 

_: 

A Possibly, yes. 

Q Who have ou talked to In additron to Marcia, If 

Ii :anyone. anout the possibi ly rty of writing a book? .^. A Oh, lets see. I have mentioned It to my husband. 

fS.And I have talked to - I have talked to - myself writing a 

:; ; book, you mean? Me? 

:. Q Well, well ’ start with you and then well ’ get to 

: i : Marcia in a second. 

--1 

--_ 

Ii! 

A Q K;T;;;k:&&a$k agent. 

A His name is - arcras ’ agent, who helped 

her book. 

Q What has been discussed on that score? 

A Well, actually it wasnt ’ about myself. And 

about whether, after this is all over, is there a possibility 

of writing a book. I wasnt ’ really sure an 

interested in a book by an aunt or a mot z 

one would be 

er. So, nothrng 

..,: __; 

__. 

_,! 

41 ‘

251 

Page 99 

. 

:i j Clinic in 2. 

I guess so. She went to something called the Rader 

But I dont ’ know what they did there. 

Q There are a couple of references on the tapes to a 

1 i1 person described as a Christian Scientist. 

z- ‘

.-, A Uh-huh. 

;‘’ Q 

iii about that? 

Who is this Christian Scientist? What do you know 

A I dont ’ know. I dont ’ know what the context of the 

13 j- what she was talking about. 

.._. Q Well, has she ever described her havin 

1: conversations ‘ with somebody that she refers to as a C 9.. ins&an 

: : I ’ Scientist? 

A Yes. Christian Science is a religion and I think 

F:; i shes ’ interested in it. 

:. Q 

jlzchurches? ’

Okay. Did she go to any Christian Science 

I dont ’ know very much about Christian Scrence 

- -. mvself. so I dont ’ - .- ,-- 

- - A 

: Q 

She may have. 

Did she ever mention goin to a Christian Science 

f f !. church beg In Washington or anywhere e 9 se? 

__ Not to me. 

,_.. Q. Did, she ever mention the names of anybody who was 

::I;. in the Chriitran Science church? .^ .: 

.--. Not to me. 

__;. 

.--. Q What about the following? Marcia wrote a book 

Page 100 

!: 1 about the three tenors. 

r-1 c-. A 

.i Q F:,k ‘ has occurred to people that she may be 

i; j interested; writiitigma book about all of these events. 

.:. .A. 

_. Q So, I want to ask you, have you heard Marcia or 

~~iMonrca talk about any plans to write a book? 

- A Well. we were told by all the attorneys, no book 

i Gi deals, nothing like that. 

[LO: Q Oka 

: :: ; Monica or Marcia 

And did you have conversations with either 

a out any book deals? 

i::j A Yes, Im ’ sure I may have. 

,71 ‘

.--. Q Oka What were those conversations about? 

(14: A May g e someday we could write a book. Thats ’ all. 

::5: Q When did those conversations take place? 

;i‘’ 

- I A Could have been within the last few weeks maybe. 

.-I ‘ 0 Who would that have been a conversation with? 

i E 2 : Would it have been with Monica or would it have been with 

r:s:Marcia? 

! 1 z : A Not with Monica. Possibly I spoke with Marcia. I_. 

,--_ Q 

;-_, __ A 

Okay. What prompted that subject to come up? 

Probably discussions about legal fees. :; ,_7‘ 

I^, 

.-_ 

r-q. 

,--_ 

Q Was it i long conversation? 

A I think several times its ’ been discussed. 

0 Several times. All over the last couple of weeks 

her with 

it was 

___- 

Page 102 

::!came of it ,^1 

._, Q 

:3; 

LIf{;; have a meeting with this agent? 

A - 

;:I Q Whats ’ the agents name? 

-q> A 

i Z t name is Paul. 

His last name is Mahon. M-A-H-O-N, and his first 

.,; Q 

iI: 

Was there a discussion of money? 

A Hmm.,just sort of, yeah, but not really, because he 

: sjdidnt ’ think that Marcia or I would real1 

: : 2 1 would be writing a book of any interes ty 

be anybody that 

to anyone. He 

; : :! thou ht if anyone writes a book it will be Monrca. And then 

: 12 1 Itol 8. hrm. well, thats ’ impossible because her lawyer has 

: : 2 1 said, absolutely nothin 

:1;: Q When 8 Id you have these conversations or 

: : 5 1 conversation with Paul Mahon? 

. _. .-7. A Probably a month ago maybe. 

::7; Q Was there only one conversation with him? 

.--. A Yes. 

:I31 Q How were things left with Mr. Mahon? 

!ZZ! A That there was no -there would be no book. There 

: 2: 1 would be no book deal. .^^, Q Did you consider going to another agent? Or did 

t:? : Marcia consider it? 

._.. .--I A Not seriously, no. 

-i- ‘

--_ Q Who made arrangements to meet with Mr. Mahon? 

Page 103 

I 11 Mr. Mahon - .-, 17. _-> 

:3: Aa idid, call you or - 

:a: A I did. 

Q Was that at your urging or was it at Marcias ’

i z i urging, or did - 

I?: A Well, actual1 originally, originally Marcia heard 

: 3 1 that Linda Tripp had starte 2, all this because she had a book 

ps.deal. So. she said something like, this is unbelievable; all 

!ioiof this was because that woman wants to make money? So, that 

i 1 I lwas one thing. 

Then she ot a letter from her publisher of her 

~i~~first book about the t R ree tenors. And somethin about 

( I 4 1 ro 

x 

alties, that theres ’ no royalty statement ; et. $0, she 

: q= I as ed me to call Mr. Mahon and find out w at was goino on i*- 

(16 j with that 

.--a - 

So I talked to him and then I asked him about a 

i 1 ii book deal fo; my sister, whether she could do it or I could 

; : 2Ido it. Then we met and he said, well, I dont ’ think its ’ you 

!:fjand her, I think ma be Monica. 

::I] Q Did?vl arcia appear to want a book deal? 

Not particularly, no. 

Did you want a book deal? 

Not particularly. 

Has anyone e se tned to contact either of you 

_______.~__ __~___~ 

OlCStarr Page 98 to Page 103 
1145 

BSA Debra Finerman, 3/18/98 

Page 104 

: : : about a bozk dF$ 

.^. 

-. 

!3’ Q Have you had an contact with either of President 

1 ij Clintons ’ aprne s, Wilitams an 

NY,. 

dy Connolly or - 

,3. 

0 Okay. One of the thin s that ou said earlier, 

14 iwhen I asked you the question who e P se drd 

i 5 j knew about the physical relationshi 

$lonica tell you 

with the 

[g;President. you mdtcated that Linda 

pT !f you wrll. 

npp dtd. 

Page 107 

Q - wanted her to star0 

;;c A Uh-huh. 

r1.. Q Then I asked you about Ashley Rarnes and about 

ifs:Cathenne. whose last name was Davis. And you said that you 

1 i3:didnt ’ know whether they knew about the relationship or not. 

jl’: ? A Uh-huh. 

::5. 0 The reason that I was wantin to follow up on that 

;:c:js that one of the things that you said during 9 he earlier 

! 17 iIntervIew. and its reflected in an FBI interview report, IS 

; I 3 that ‘ you had met Ashley Raines,, and that Monica had told 

I: s;Raines about her relationshio with Clinton. ,--, 

i23: A Hmm. 

Q So. I guess what I am asking you is, did you 

i$ j understand that Monica had told Ashley Rattles about the 

[:x!relationshii with Clinton? 

Yes. I guess she told her something, but I didnt ’

li”, 1 know how much Ashley knew. 

Page 105 

[I: Q Okay. Another thing you said was that Lewinskys ’

:l;fnend. Catherine, last name unknown, also knew about 

i3! Lewinskys ’ relatronshi with Clinton. 

:4: A ? 

Q 

Really. Catherine in Hawaii? 

15: Yes. Well, formerly in Hawaii, now - 

i6i 

7: ‘ A0 l-guess- somewhere else. 

;0: ,-j A Maybe. yeah. 

i3: 0 What is your best recollection now about whether 

11 c]: Catherine or Ashley Rames knew about the relationship with 

l;?:Clinton? 

1::: A I dont ’ know. At the time of the interview - I 

::3;guess Ashley knew something. Ashley was her only loyal 

[ : 4 1 fnend. 

(15: Q A ain, Im ’ real1 

[ :s 1 Monica tell you a % out other of i 43 

focusin more on what things did 

er fnen s that she had told 

; 1: :about the relationship with President Clinton? 

A 

iii i Catherine? 

Thats ’ all. I didnt ’ - are you sure I said 

i-2: Q Well. thats ’ what the - 

i2:: A 

{Zl: Q ?,hat?),k?.yhat the interview report said. 

Y3- ‘ A Oh, okay. 

124‘ Q Sometimes mistakes get made, but thats ’ the reason 

r:i!why we follow up and ask and try - 

Page 106 Page 109 

i1: 

I?: Aa Okay. - to 

9 

et clarifications. 

[31 A I don remember thinking that Catherine knew 

i 4 1 anything. I was shocked when you flew her here. So, Im ’

15; sorry I said that. I dont ’ know. 

!5: Q All ri ht. 

;7- BY MR. &OLF: 

Q I just have a few followup 

i z i earlier your questioning what did Vernon 9 

uestions. We discussed 

ordan have to do 

.;olwith Monicas ’ finding a job. I would like to follow up and 

11: ask another question. 

l-” 

I 3 j Monica get a la 

What di:pmon Jordan have to do with helping 

14: A lv%nt ’ know. Somehow he got her a lawyer. 

15j 0 Do you know how that came about? 

(16: A No. 

Q 

I ii i get a lawyer? 

Did you ask her, why was Vernon Jordan helping her 

I19: A Im ’ trying to remember. No, I dont ’ think I asked 

[:o!that. 

(2’ A. ’ Q Did you think it was unusual? 

1221 A Yes. 

iZ3; 0 Is that why you formed a connection that the job 

[ 2 4 ; was related to her si nin whatever it was they - 

[25: A Yes, ?thin\ so. 

:‘ve Y interested in Monicas ’ rivate life. And Monica told me 

:: tha she told her all kinds o P. things. 

: I told you she told her she was psychic. It seemed 

; i to me she was very meddlesome and I think I thought she was 

-. cobsessed ’ with Monica. 

F‘ 0 Did Monica buy into Ms. Tri 

I i about her interest in sorcery? Is Monica P 

ps ’ representation 

in erested - 

:- A I dont ’ know that it was sorcery. :^_ .j. Q in that sort of thin ? . 

. “. A No 

:f i that woman had pi 

not at all. But I ? hink when she was told that 

chic powers,. I think it interested her. 

.T. _L 0 An v-! hina bevond lust beina interested from an 

i:~jacademic oint of-view? _ . - 

1:4: Al Not that I know of. 

[?5: 0 Did she ever tell you or discuss with you an talks 

; 1~:she might have had with Ms. Tripp about her being a possr .g. le 

L :: 1 witness in the Jones case? 

[li: A No, not that I know of. She didnt ’ tell me that. 

Q Did she ever talk to 

:i?: points? Do you know what I mean b 

ou about any of these talking 

A 

y that? .^I !--. I do. I saw them in the newspa 

if 

er. No. 

f^^‘ 

,--. Q Youve ’ never discussed that w h Monica at all? 

,--.. 

,--_ A Not before no. And not after. So. no. 

!Z:: Q So, never? ’

t25: A Right. I dont ’ know who wrote those and I dont ’

Page 104 to Page 109 

XMAX(l8) 

:_ 

.- A Uh-huh 

T Q What did Monica tell you aoout Frank Carter, what 

: r : he was doing for her7 

:‘‘ A I dont ’ know. He was - I dont ’ know. He was 

:c.writing up something. 

Q In connection with what? 

:;. A I didnt ’ know at the time. Now, I know, but I 

i !: didnt ’ know then. 

Q Werent ’ you curious enough to ask? 

A 

!!!-I didnt ’ know. 

No, not - no. Now it IS important. At the time. 

: .-- Q Well. usually when people get lawyers Involved, 

: :; its ’ bad news. It didnt ’ cause you any concern that she was 

. ‘ __ =. needin 

~. lawyer. 9 a lawyer, that Vernon Jordan was taking her to see a 

..c 

,._. 

.- A Not particularly. 

3-c. 

.--. Q Do you know anything about a blue cocktail dress 

: : 2. that Monica ma have had? .?_. 

.-_. A &ue? No. Blue cocktail dress? ._I.. 

,-- Q Or a dark-colored cocktail dress? .^_. 

_--_ 

:_2, seen anything like that? .^ ,. ,-*. red one. No, I dont ’ know. 

r-z- _--. Q Did you discuss with Monica what you were going to 

Page 108 

: : : be asked iboutN;re today? 

[Z: 

7. ‘<-. Q 

; y ; these matters? 

When was the last time you talked with Monica about 

A ARer the lawyer said, you dont ’ discuss the case, 

i r. we do not discuss the case. 

._ Q 

!f 

When was that? 

A As soon as - as soon as I got a lawyer. As soon 

?-as she aot a lawver. 

I _ : 

,-- - Q S'o, youill‘ A 

: :z : FBI took her - 

She told me, from the very day, the day that the 

(13: Q Janua 16th? 

-4: ‘ A Right. x e were told, you do not discuss this. You 

i 1:. never talk about any of this at all. 

; Q 

if”for you with - 

Have you authorized anyone else to talk about it 

_: 

_-- 

: 1 ? Aa N_“-- 

: ‘ I reoresentatives? 

either her representahves or your sisters 

^.. A My lawyer talks to her lawyers. Yes. 

--. 

--. Q Can you tell us what sort of discussions you had 

__ - :-with Monica about Linda Tri 

:;- A Sure. Yes. e 

p? 

inda Tripp, as I said already, was 

--. - =. this strange woman at the Pentagon who is much older, and 

~ 

OlCStarr 
BSA -_. 

1146 

Debra Finerman, 3/18/98 XMAX(19) 

Page 113 

;:: Q Did she continue to be interested in drama and the 

I -I activitres vou described before? .- 

[3’ A ‘ Yes, uh-huh. I thank so. 

ii: Q Did she ever have any krnd of problems in htgh 

[ 5 I school of ~whc$e~e~~rugs or - 

!6: 

[7] 

Fe! 2 

- anything like that? 

Never. No problems. 

!Gl Q 

!:g!right? 

Now, Monica went off to junror college first, 

!:li A 

[:I?; Q 

Right. uh-huh. 

Did she do well? 

[I31 A Yes. She did ve 

7 

well. 

0 And as a result o 

1:: j Clark CollLge. right? 

that, she went to Lewis and 

LIEI 

Q 

iii jschool on ;he West Coast, right 

RA,gdh~hat ’ s ’ a prey high-quality liberal arts 

1151 Yeah, I uess. 

[?!I! Q Do you i? now how well she did there? 

[??I A 

[?21 0 

I dont. ’ but I think. she was a good student. 

I'31 

She graduated, rr%ht? 

A Yes. She majore In psychology. 

[?41 Q 

i:51 A, 

,D;oy;E:hink of Monrca as a trustworthy person? 

Page 110 

r L 7 _ 1 know anything about it. 

r: Q Have you ever heard any phone messages on Monicas ’

[j.machine. or on an 

14 ;be from the Press .rI 

machme. that were represented to you to 

ent? 

15: A No. I didnt ’ hear. 

16‘ Q Did she ever tell you that she had received phone 

I 7. messaaes from the President? 

Messages? No. But she told me about the phone 

What did she tell you about the phone calls? 

That she got those phone calls in the middle of the 

Did she ever tell you what they talked about? 

No 

You werent ’ curious to ask? 

No. 

Okay. We were talking about nicknames before. 

Right. 

Have you ever heard the nickname Babba. The Babbao 

Yeah. 

In what connection have ou heard that? 

Hillary Clinton is The Bab L a. 

Who aave her that nickname? 

Moni& I guess. 

Do you know where she got that from? 

Page 111 

[l! A 

Q 

It means grandmother, old lad or something. 

Do you know why she referre 

i j i why she gave her a nickname? 

8 to her as The Babba, 

141 A Just for fun. No. Just for fun. 

I51 Q 

A 

What did she say about Mrs. Clinton? 

[6j I dont ’ know. She never talked about her much. 

11 ’ Q Well, when she was referred to as The Babba. how 

i 9 i did that come up? 

A 

; : z 1 something 

I dont ’ know. The Babba is out of town, or 

like that. 

,..- .A_, Q What would that mean? 

[:j A 

113; Q 

That would mean Hillar-y Clinton was out of town. 

.:4’ A 

Would that be of special significance to Monica? 

Yes. because I thank thats ’ when she aot invited to 

jIj;go there, when his wife was not around. 

Ii61 MR. UDOLF: Thats ’ all I have. 

,7‘ ’ 

.- BY MR. BINHAK: 

._. ‘ Q You will be happy to know that Mr. Udolf asked some 

i 1 G Iof my questtons. 

,^n. 

.--. A Okay. 

?: ‘ 1 Q I wanted to ask vou some auestions about Monica 

A Okay. 

0 Monica grew up in Los Angeles, right? 

i24! A Yes. _ 

;.5: Q Did you have any contacts with her when she was a 

Page 112 

, I lvounaer child? .._ _ 

[2: A Yes, I did. 

I:; 

Q er kid? 

A 

What was she like as a youn 

She was very outgoing and s ?I e was very strong- 

[slwilled. and she pretty much did what she wanted. 

/:j 

Q What were her interests? 

A Her interests were drama. She was a beautiful 

[B]$nger. She has a beautiful singing voice. Fashion. Thats ’

[9lfi. 

[lOI Q Did she have friends as a child? 

[Ill A Yes. 

.--, ,,?I Q A lot of friends? 

[I31 A Uh-huh. 

i:liwell? 

Q And did she do okay in school, or exceptionally 

[16i A 

Q 

She did ve well I think up until hi h school. 

[I71 Did she pa 

r$ * 1. R 

A Uh-huh. 

rcrpate tn acbvrtres in SC ool? 

[I81 

Q So would it be fair to say that she basically had 

ifi;a pretty normal childhood? 

[2lj A Yes. 

Q You said u 

P. 

until high school she did pretty well. 

tiz;Did she continue to do we I in high school? 

A I dont ’ think so. I think in her last two years of 

If:; high school she didnt ’ get very good grades. 

Page 114 

[II Q In your experience, is she an honest person? 

I:; 

A Yes. 

Q In your ex 

14 1 stories or p fantastes. F rience. does she make things up or tell 

I51 

Q 

No, not really. 

Well, let me ask 

Itjwhen Monica became intereste J. ou this question. Do you know 

[ 8 IWashingtol? 

in polrtrcs or in coming to 

[91 I think with her internship she became extremely 

110 1 interested in polrtrcs and she became very knowledgeable. 

Q 

iii; before she came to Washington? 

Did she have an Interest in politics and Washington 

[I31 A No. 

[I41 Q So, that was something that was an opportunity that 

;;;;=me along? Right, 

Ii71 Q 

I:s!say? 

And that ignited her interests? Is that fair to 

(19: A Yes. 

[2Gj Q Was Monica a supporter of President Clintons? ’

i! ‘ 1 j--. A I dont ’ know. 

Q You dont ’ know whether she was a Democrat or a 

ii:iRepublicaz or whether she - 

[241 She was in colle 

[25! 0 Once she starte % 

e at the time. I have no idea. 

working at the White House, do you 

Page 115 

[ 11 know whether she was a supporter of the Presidents politics? 

I:; 

A Yes, she was. 

Q When she left the White House and went to the 

14 IPentagon, do you know if she supported the Presidents 

(5 1 policies? 

(61 A Yes, I think she did. 

[71 Q 

[alas a person? 

Do you know if she thought highly of the President 

[91 A Yes, she did. 

I101 Q 

illi 

How do YOU know that? She told vou? 

A Yes. _ 

I 

1121 Q You said just a couple of moments ago that you 

[ 13 1 considered Monica to be trustworthy and an honest 

[ 14 1 basically didnt ’ make things up and didnt ’ fantasize? 

person who 

[151 A Correct. 

Q Did you believe Monica when she told you about 

I:7”{ kissing the_ Presjdent? 

1181 A Yes. 

Q Did 

~:~~called the sink incr .lIr ent? 

ou believe her when she told you about what is 

[2li A Yes, I believed her. 

[221 Q Did you have any reason not to believe her? 

1231 A No. 

Q Did you believe her when she told you that the 

I::; President was calling her late at night at home? 

oic-starr Page 110 to Page 115 
1147 

BY Debra Finerman, 3/18/98 XMAX(20) 

Page 116 

A Yes. 

Q Did you think that was strange that the President 

1- of the Unrted States would call a 24-year-old woman at home? 

Page 119 

!:: A Rrght. 

._, C Now, you said that vou had come to that conclusion 

iji based on n-at Monica Lewrnsky w-as telling you about these 

; 4 1 visits. 

,:, 

/ h;~tt;~&~~~~~ alout? to ‘ what are you refernng? What 

en ou sa the words “something was happenmg”. 

A Yes. 

-T 

.- Q 

.I A 

Why is that? Why did you think that was strange? 

Because hes ’ married. Thats ’ why 

Q 

: E man was callin 

Did you think it was strange just because a mamed 

her late at night, or - 

- - did you think It was strange that the - 

A Well, yes. 

._ Q So, both? 

A 

Q 

Both things were ve strange. 

-1 What about the fact r hat he was a married man made 

: 2. you think it was strange that he was calling Monrca late at 

-: night? .-- 

..-. A Because shes ’ a single woman and hes ’ a mamed man 

:: and I didnt ’ think that was right. 

Q You didnt ’ think it was appropriate? 

A Correct. 

0 Mr. Udolf asked you just a moment ago if you knew 

iff :what they were talking about, and you said, no. 

-_ A Right. 

.-r Q You thought it was an inappropriate thing for him 

if 5 : to be calling her and - 

Page 117 

._. ti Fed.. 

i<:calling her, but - 

she discussed with you the fact that he was 

,: 

A0 Fght. vou didnt ’ discuss with her what they were 

i z : talking about? _ 

._ A No. 

:_ Q Not once? 

A 

..: 

Not that I can remember. 

Q Did you describe to her that you felt that it was 

\ !! : inappropriate that a married man was calling her? 

-_ A I ma 

i 

have. But I. I think I explained to you in 

: : 3. the interview that w en Marcia expressed her disma at what 

.:; -was going on here, she clammed up and wouldnt ’ te Y I Marcia 

-: 

. 

__ 

-_ __ 

anything else. 

So, Marcia said to me, could you just see whats ’

-going on when you talk to her; dont ’ tell her you.think thus 

IS ‘ disgustin , dont ’ tell her how we feel about thus. that 

there was $one.calls and thrngs gorng on. 

o I drd not sav. oh, thats ’ horrible, thats ’

disgusting. ‘ hes ’ awful. I did not. I just listened. 

Q Did our sister continue to tell Monica that she 

-didnt ’ approve of w l? 

A 

at was going on? 

Im ’ sure from time to time she absolutely did. 

Q So, is it fair to say then that your role was more 

Page 118 

.:. to gather intelligence without passing judgment, and in that 

: I : role Marcia Lewis asked you not to pass judgment so that you 

I-. could continue to aather rntelliaence? 

.;: A Yei. 

-z- 0 

’ ; : Marcia Lewis? 

And then you would relay that information back to 

._. 

:?: A 

Q 

I wouldnt ’ always tell her details. 

When 

: 3: report back to her tha ty 

ou say you wouldnt ’ tell her details, did you 

the 

;:::night? 

President was calling Monica at 

. . A Im ’ notsure. Idont ’ remember. I may have. I 

I.!don ‘ t ’ know whether she knows or not. So. I dont ’ know. 

: : 1 j Because we cant ’ discuss this matter. So. I dont ’ remember. 

Q Well Im ’ not asking you whether she knows, because 

ii! f you cant ’ really know what she knows. Im ’ asking - 

. _: 

.-:. A Do I remember tellin her? 

_- Q %er- 

. _: 

Yes. Do you remem 

._: A I dont ’ remember. I dont. ’

_^. Q 

:: :-her duringAhat 

Is that the kind of thing that you would have told 

IF 

riod of time? 

.--. 

Q 

aybe. but I dont ’ remember doing it. 

You had described before, in response to one of Mr. 

is; Emmick ‘ s ’ questions, that something was happening - that was 

: :; : the term you used - between the President and Monica 

: I: : Lewinsky. 

Page 116 to Page 121 

. 

19: k 

[l;; 

jll‘ : 

11: ! response. 1 

113: 0 

;iq:mrnd? 

:I51 b 

1:i: U 

It did not until she sard that sink thing. 

But it definitely haa an emotional component to it? 

117, A Yes. 

2‘ Q Did you connect that to what was bothering Monica? 

I: i j You said tr.at Monica was distressed and emotional and - 

iZ:: 

I::1 ko Fight. 

izzjthings? 

somewhat deoressed. Did YOU connect those two l 

A I think so but Im ’ not sure it was - yes. But 

If:ialso because of the wayshe ’ was being treated by her 

t3 5 1 coworkers and her superiors. 

Romantic relationshi 

A romantic relations t? 1p7 

(Vvtiness nodded indcatmg an affirmative 

Did that have a physical component to it in your 

Page 120 

Ill 0 Did the way she was bein 

9 

treated and her emotional 

12 lstate and moods. in conunction ‘ with wha she told you, did 

13 1 that lend credrbility to w CI 

I 4 1 was hapoenna? 

at she was telling you about what 

i5i ’ A -Yes. 

Q Gid you personally ever tell Monica to break off 

I t i contact wrt? the President? 

Did you believe that Monica was fairly 

I: ; I charactenzed as a stalker? L--1 

:I61 A No. 

[ 19 j relationship that you 

:2o!have? 

[?;! 

[-‘1 ‘

$ vist understand why they thought that, you mean? 

[l?] A I understood they thought that because they assumed 

134 1 its ’ her far.& or she, she is the one who is aggressively 

czjlseeking to oe near him. 

Page 121 

Q 

j 1 i whv she was Bia Red? 

You said that Ms. McCoy was Big Red. Do you know 

.~. _ 

A Because she wears red lipstick and she has big red 

t: i lips. And she has red hair. 

Q Oka 

r 

When you spoke to Walter Kaye and he 

Iz i expressed the fact hat the people at the White House were 

17 1 basically taking about this relabonship and accusing Monica 

[ 3 1 of being a stalker - 

[91 iTi !ghIS that ” before or after Monica had told you 

I :y i about the physical contact that she had with the President? 

I121 A Hmm. Thats ’ a good question. Im ’ - I dont ’ know 

t13lexactly, I mean. 

[14: Q 

tlslhim? 

Is that the kind of thing that you would have told 

[161 A No. I dont ’ think I told him that. No. 

Q What woufd Monica do to prepare to see the 

I :i ; President? You said you saw her on a few occasions to 

[I RI prepare to see the President. What would she do? 

[101 A Like blow-dry her hair, put on makeu 

0 Did she ever have a stylist come an 

I;i iorder to see the President or cut her - 

s do her hair in 

[231 

(241 ci I read that. 

I-751 A 

- hair especjally? 

But I don t think so. She may have gone to the 

OlC-stmr 
1148 

SSA 

Page 122 

Debra Finerman, 3118198 

: : beauty parlor, but I dont ’ think she had someone come there. .^ 

.-. MR. BINHAK. Thats ’ all I have. 

i .-. BY MR. EMMICK: 

;:: Q I wanted to ask a couple of addrtanal 

t3 

uestlons 

: s.One subject that we hadnt ’ touched on was whether ontca 

~6 Lewinsky talked to you at all about the Kathleen Willey 

:-:situatlon. 

A Uh-huh. 

Q Did she have any conversations with you about 

3: Kathleen Willey? 

A You know, a long time, Ion 

I ‘ remember that she said somethln 

lorg trme ago I 

-. 3 confusng. Something about Kath 9 een Willey, Linda Tripp. It 

about 9, hat, and It was very 

* “made no imoression on me. Yes, she said something. Long, 

: : 5: long. long twine ago. 

i i. ’ the summer of last year. 

Q Long. Ion-i, as in a couple of years ago? Or asin 

.,_: A Long before that, I think, like in the spring 

j i >! maybe. I dont ’ know. 

1::: Q The s 

,-. 

,--_ A Uh-hu t 

ring of 97. ‘ you mean? 

I think so. I dont ’ know why I think 

Q Do you remember what it was at all that was 

12:jconfusing and - . 

i-5: A No, no. Kathleen Willey. something-something, 

Page 0 

! : -Linda Trip 

;z,what rt is. g 

I dont ’ know. Newsweek. Now, I guess I know 

ut at the time its ’ like Greek. I didnt ’ know 

i 3 jwhat shes ’ talkin about. 

:i‘ MR. E B MICK: 

15; THE WITNESS: 

Okay. Thank you. 

Thats ’ all? f ~_ : MR. EMMICK: Thats ’ it. 

: (Whereupon, at 6:06 p.m., the proceedings were 

: : : concluded.) 

: l . . . . 

:: CERTIFICATE OF COURT REPORTER - NOTARY PUBLIC 1 : I. Elizabeth A. Eastman, the officer before whom 

IEthe ’ foregoing deposition was taken, do hereb certify that 

; 3: the witness whose testimony appears in the Y oregoIng 

1; : deposition was duly sworn by me; that the testimony of said 

=.witness was taken by me electronically and thereafter reduced 

:z. to t 

: -. of t x 

pewriting by me; that said deposition is a true record 

e testimony given by said witness; that I am neither 

: 3. counsel for, related to. nor employed by any of the parbes 

:? to the action in which this deposition was taken; and, 

_. - - -further. that I am not a relative or employee of any attorney 

__ - -or counsel emplo 

11 .otherwlse interes ty 

ed by the parties hereto, nor financially or 

ed In the outcome of the action. 

- ; 

,--. 

,-. 

.-7. IC I-UK THt 

.“_ DISTRICT OF COLUMBIA 

.--My Commission Expires: 

XMAX(21l 

OlCStarr Page 122 to Page 0 
.- 

1149 

Office of the Independent Counsel 

March 16, 1998 

Steve Gordon 

Holland & Knight 

2 100 Pennsylvania, NW 

Washington, D.C. 20037 

Bv Mail and Facsimile (702) 955-5564 

Re: Cooneration/Immunitv Agreement. Debra Finerman 

Dear Mr. Gordon: 

The purpose of this letter is to set forth the terms of the cooperation/immunity agreement 

that has been reached between the Office of Independent Counsel and your client, Debra 

Finerman. 

Let me first summarize the background of the agreement. As you know, we are 

investigating whether Monica Lewinsky and/or others committed perjury, suborned 

perjury, obstructed justice, intimidated witnesses, or otherwise violated federal law in 

dealing with witnesses, potential witnesses, or others concerning the civil case JQKUZ v. 

Clinton. Our Offtce determined that your client has information relevant to that 

investigation, and last month we asked to interview your client. You indicated that your 

client, based upon your advice, would invoke her Fifth Amendment right not to be 

compelled to incriminate herself, and you asked whether our Office would offer her 

immunity from prosecution. Our Office indicated we would consider offering such 

immunity. However, we would need to conduct an in-person proffer-interview of your 

client in order to obtain sufficient facts to determine whether immunity was appropriate in 

view of the information she possesses, and in view of any role she may have played in the 

events we are investigating. The terms of the proffer agreement were set forth in a letter 

from our Office dated February 19, 1998. We conducted the proffer-interview on 

February 2 1, 1998. 

: DEPOSITION 

f EXHIBIT 
1150 

We have reviewed your client’s proffer, and we have determined that, in order to provide 

the grand jury with the benefit of the information possessed by your client, it is 

appropriate to offer her immunity in exchange for her truthful, complete, and candid 

cooperation with our investigation. 

Let me clarify the terms of this cooperation/immunity agreement. On her part, your client 

agrees to cooperate tilly with the United States, including agents of the Federal Bureau of 

Investigation (FBI) and any other law enforcement agencies the United States may 

require. This cooperation will include the following: 

1. Ms. Finerman will provide truthful, complete, and accurate information to the 

United States. She will provide, upon request, any documents, records, or other tangible 

evidence within her custody and control relating to the matters about which she is 

questioned. She will assist the United States in gaining access to such materials that are 

not within her custody and control, and she will assist in locating and gaining the 

cooperation of other individuals who possess relevant information. She will not attempt 

to protect any person or entity by providing false information or omitting relevant 

information, and she will not attempt to implicate any person or entity falsely. 

2. Ms. Finerman will testify truthfUlly before grand juries in this district and 

elsewhere, at any trials in this district and elsewhere, or in any other proceeding, as the 

United States may require. Neither she nor her agents will explicitly or implicitly, 

directly or indirectly, contradict this truthful testify or the information she has provided to 

this Office in any setting, including news interviews, books, articles, speeches, or other 

public statements. 

3. Ms. Finerman will consent to interviews conducted by the United States, 

including attorneys, law enforcement agents, and representatives of any other institutions 

the United States may require. She will make herself available for these interviews upon 

request and reasonable notice. The subjects about which Ms. Finerrnan will cooperate 

include all subjects within the scope of our investigation. 

4. Ms. Finerman will submit to a polygraph examination upon request by the 

United States. 

5. Ms. Finerman will waive all privileges, without limitation, except as to your 

representation of her and as to her communications with her husband. 

2 
1151 

If your client fully complies with the terms of this agreement. our Office promises not to 

prosecute her for any crimes committed prior to the date of this agreement. arising out of 

the events we are investigating. That is, your client will have “transactional immunity” 

from prosecution by this Office. 

If our Office determines that Ms. Finerman has intentionally given false, incomplete, or 

misleading information or testimony, or has otherwise violated any provision of this 

agreement, this agreement shall be null and void. Your client will then be subject to 

prosecution for any criminal violation of which this Office has knowledge, including but 

not limited to perjury, obstruction of justice, and making false statements to federal 

agencies. In such a prosecution, any statements or other information provided by your 

client in the course of her cooperation or her proffer may be introduced against her. 

If the terms of this cooperation/immunity agreement are acceptable, please sign, and have 

your client sign, in the spaces provided below. 

MICHAEL W. EMMICK 

Associate Independent Counsel 

Steve Gordon 

Counsel for Debra Finerman 

Debra Finerman 
824-DC-10 

15/02 '97 IS:30 TX/RX NO.2122 P.001 

m 
1153 

-I 

I 

n -I I. 

:, 

- 

u / 

_- 

mlrr I _Dwm.~b”.“?.. .^_ 7.. 

P.002 

a 
1154 

8%DC-00000012 

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1167 

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

- 1 - 

OFFICE OF THE INDEPENDENT COUNSEL 

Dare of nanrripion 3/22/98 

JAY KERRY FOOTLIK, white male, date of birth 

_, plac 

Security Account Number 

telephone number 

apprised of the official identities of the interviewing Agents 

and the nature of the interview. FOOTLIK was interviewed at the 

office of his attorney, DARREN BERNHARD, HOWREY & SIMON, who was 

also present for the interview. FOOTLIK provided the following 

information: 

FOOTLIK graduated from the University of California at 

Los Angeles (UCLA), School of Law, in December of 1994. In 1992, 

FOOTLIK worked in the Los Angeles office of the CLINTON/GORE 

Presidential Campaign. During 1992, FOOTLIK met MONICA LEWINSKY 

at a Century City Mall tie store, where LEWINSKY was employed. 

LEWINSKY gave FOOTLIK advise on ties and they spoke generally 

about politics. LEWINSKY asked for, and received, FOOTLIK's 

telephone number, and they stayed in sporadic contact. 

FOOTLIK moved to Washington, D.C., after the 1992 

Presidential Election. FOOTLIK worked on the Presidential 

transition under CRAIG SMITH. After the Inauguration, FOOTLIK 

worked for the Democratic National Committee in Washington, D.C. 

In August of 1994, FOOTLIK moved to the White House, in the 

Office of Presidential Personnel under CRAIG SMITH. FOOTLIK's 

interaction with LEWINSKY, up to this point, was sporadic. 

At one point, in 1994 or 1995, LEWINSKY called FOOTLIK 

inquiring about internships at the White House. FOOTLIK advised 

LEWINSKY about the Intern Office in the White House. Sometime 

after LEWINSKY began her internship at the White House, LEWINSKY 

mentioned that WALTER KAYE had helped get LEWINSKY the 

internship. LEWINSKY also mentioned that someone in her family 

had a place at the Watergate Apartments, and that LEWINSKY would 

be staying there. 

When LEWINSKY was an intern and a staff member, 

LEWINSKY would call or stop by FOOTLIK's office at the Old 

Executive Office Building (OEOB). FOOTLIK thinks LEWINSKY felt 

FOOTLIK was more of a friend than he felt of her. FOOTLIK did 

Investigation on 3/19/98 at Washington, DC File I 29D-OIC-LR-35063 

Date dictated 3/22/98 
1168 

OK-3OZa (Rev. 8-19-94) 

29D-OIC-LR-35063 

Continuation of OK-302 of JAY KERRY FOOTLIK ,On 3/19/98 , pl_ec 2 

not socialize with LEWINSKY outside of work. FOOTLIK and 

LEWINSKY went to lunch a couple of times in the OEOB cafeteria_ 

Sometime after the assassination of Israeli Prime 

Minister YITZACH RABIN, LEWINSKY came to FOOTL*IK and mentioned 

she had a Christmas present she wanted to give the President_ 

FOOTLIK suggested LEWINSKY send the gift through the 

regular inter-office mail. LEWINSKY was more insistent in giving 

the gift to the President in person. LEWINSKY asked FOO_TLIK to 

walk her over to the West Wing, as she did not have a pass that 

would allow her to walk unescorted into the West Wing. FOOTLIK 

did not want to walk to the West Wing without an official 

purpose, so he kept putting LEWINSKY off. 

Shortly thereafter, FOOTLIK had a reason to go to the 

West Wing. He told LEWINSKY this, and the two walked to the West 

Wing together. FOOTLIK wanted to give CLINTON a button that 

memorialized CLINTON's eulogy to RABIN. When LEWINSKY and 

FOOTLIK got to the West Wing, a birthday party was being held in 

the anteroom of the Oval Office. CLINTON was at the party, and 

FOOTLIK gave the button to CLINTON at that time. LEWINSKY then 

gave CLINTON the tie. FOOTLIK left CLINTON and LEWINSKY standing 

in the hall, as FOOTLIK mingled at the party. FOOTLIK visited at 

the party for a couple of minutes. 

FOOTLIK then told LEWINSKY he had to get back to the 

OEOB, but LEWINSKY did not want to go. FOOTLIK felt obligated to 

escort her back because he had brought her to the West Wing. 

LEWINSKY acquiesced and left with FOOTLIK. FOOTLIK recalls the 

White House photographer being present when he was meeting with 

CLINTON, and believed a photograph existed of this meeting. 

LEWINSKY seemed to enjoy her position at the Office of 

Legislative Affairs. Around the time of LEWINSKY's transfer from 

the White House, LEWINSKY called FOOTLIK very upset. LEWINSKY 

mentioned to FOOTLIK that she was perceived as being chatty or 

talkative. LEWINSKY never mentioned concerns about EVELYN 

LIEBERMAN. LEWINSKY never mentioned being described as a 

"stalker" or a "clutch." FOOTLIK remembers LEWINSKY mentioning 

her job at the Pentagon the day she told him she was being 

transferred. FOOTLIK was not surprised LEWINSKY was transferred. 
1169 

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

29D-OIC-LR-35063 

Continuation of OK-302 of JAY KERRY FOOTLIK ,On 3/19/98 ,page 3 

After LEWINSKY left the White House, FOOTLIK had little 

contact with her. At one point, LEWINSKY asked FOOTLIK to 

dinner. FOOTLIK went to dinner with LEWINSKY to be nice. 

LEWINSKY mentioned her job at the Pentagon, the travel related to 

the job, and other general topics. LEWINSKY seemed to be happy 

at her job and never mentioned coming back to the White House. 

In July of 1997, 

the Pentagon City Mall. 

FOOTLIK met LEWINSKY, by chance, at 

FOOTLIK and LEWINSKY spoke for 

approximately thirty seconds. 

When the news about LEWINSKY broke in January of 1998, 

FOOTLIK called CRAIG SMITH at the White House and told him what 

he knew of LEWINSKY. A week or so later, DAVID KENDALL called 

FOOTLIK and interviewed FOOTLIK about the LEWINSKY matter. 

FOOTLIK advised the interview encompassed everything FOOTLIK has 

discussed in his interview with the Federal Bureau of 

Investigation (FBI), documented in this FD-302. 

FOOTLIK never met KATHLEEN WILLEY. 
1170 
1171 

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

- 1 - 

OFFICE OF THE INDEPENDENT COUNSEL 

Date of nanscnpt~on 2/9/98 

LEWIS C. FOX, White male, born October 23, 1943, Social 

Security Account Number -, was interviewed at his 

residence, 

telephone 

advised of the identity of 

at which time he was immediately 

interviewers and the purpose of the 

interview. FOX provided the following information: 

FOX retired from the Uniform Division of the U.S. 

Secret Service, White House Detail, on January 4, 1997, after 

27 years and 3 months of service. FOX usually worked a normal 

shift from 4:30 a.m. to 1:00 p.m., but frequently worked overtime 

until 6:30 p.m. some evenings. FOX worked many weekends_ When 

the news services were mentioning the name of MONICA LEWINSKY . 

almost constantly last week, FOX was asked by some of his 

friends, who gather at a restaurant in Waynesburg, whether he 

knew LEWINSKY. He replied that he did, and this apparently 

resulted in one of them notifying News Channel 11 in Pittsburgh, 

who requested an interview. FOX was interviewed at his home 

several days ago. 

FOX received a call from First Name Unknown (FNU) 

JACKSON of the Bureau of Public Affairs, of the Secret Service in 

Washington, earlier in the day. FNU JACKSON inquired whether he 

was going to grant any more interviews and, after some kidding 

around, FOX replied that he was not. JACKSON advised him that as 

a result of the television interview he may get subpoenaed. FOX 

said that he had nothing to hide, and was willing to provide any 

information that did not affect the security of the President. 

FOX first met MONICA LEWINSKY when he was on duty at 

the Control Point in the basement of the West Wing of the White 

House. LEWINSKY was wearing an III" badge, indicating that she 

was a White House intern, and was accompanied by another young 

lady who was. introduced as a friend from California. MONICA 

stated that she wanted to take her friend, who had a visitor's 

badge, upstairs for a limited tour of several rooms.. FOX pointed 

out SUSAN LEVINE, of the Democratic National Committee, who was 

about to escort several persons from Arkansas on a private tour. 

LEVINE agreed to take MONICA's friend, and MONICA agreed to wait 

at the Control Point for her to return. A few minutes later the 

Vice President came downstairs and passed by, going across the 

Invesngadon on 2/6/98 at Waynesburg, Pennsylvan&&, 29D-OIC-LR-35063 

Date dictated 2/6/98 
1172 

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

29D-OIC-LR-35063 

Continuanon of OK-302 of LEWIS C. FOX ,On z/6/98 .Pagc 2 

street. Then the President passed by on his way to the Executive 

Office Building and waved at FOX, MONICA, and the other officers. 

The tour returned and the President stopped by on his return from 

EOB and shook their hands and had his photograph taken with the 

visitors fromJ&&ansas..% The President also took a photograph 

with MONICA, but it did not appear that he knew her at that time. 

FOX explained that MONICA could obtain an autographed copy of the ’ 

photo by making a written request. This made MONICA very happy 

and she inquired, "LEW, do you like chocolates?" FOX replied 

that he did. 

About one week later MONICA called him at his post from 

downstairs in the White House and came up to see him. MONICA 

thanked him for his helpfulness in obtaining the photograph with 

the President and gave him a box of Godiva chocolates. Thereafter, FOX's fellow workers would always refer to MONICA as "your 

girl" whenever she was seen in the West Wing. FOX explained that 

this was their way of kidding him, but that he had no social or 

outside relationship with LEWINSKY. After the chocolate affair, 

FOX would periodically see LEWINSKY in the Executive Office 

Suilding or in the halls and they would always speak to each 

other. Several weeks later MONICA said that she was getting a 

permanent pass to the West Wing, after she obtained a paying job 

in the Congressional Offices in the East Wing. FOX remarked that 

MONICA had obtained a job much quicker than most of the interns 

that he has known. 

FOX soon started seeing MONICA carrying file folders 

from the Executive Office Building to BETTY CURRIE's office in 

the West Wing. FOX stopped by MONICA's office several times to 

say hello. MONICA always appeared to be very busy. 

FOX stated that he was on duty outside the Oval Office 

on a Saturday or a Sunday, probably about 12:30 p.m. or 1:30 

with a. Secret Service Agent when the President opened the 

ZoIr'and asked "Have you seen a young congressional staff 

member?" and he and the Agent replied that they had not. The 

President said, "I'm expecting one." FOX stated to the Agent, 

whose name he does not recall, "I'll bet it's MONICA." About ten 

minutes later MONICA LEWINSKY showed up with some letters for the 

President. Either FOX or the Agent knocked on the door of the 

Oval Office and the President said "Yes" and opened the door of, 

the Oval Office. MONICA walked into the Oval Office and the 
1173 

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

29D-OIC-LR-35063 

Continuation of OK-302 of LEWIS C. FOX .o,, z/6/98 . Page 3 

President said "She'll be here awhile" and the door was closed. 

This occurred on a Saturday or a Sunday, month unrecalled. A 

nearby television set had a football game on, which they were 

intermittently watching. MONICA was in the office for an hour or 

more. 

On one other occasion, on a Saturday or Sunday 

afternoon, FOX was down the hall from the Oval Office and 

observed LEWINSKY come out of the Oval Office, but he did not' 

observe her enter. This occurred in the afternoon, time unknown. 

MONICA returned to the East Wing but did not see FOX. 

Fellow officers began remarking that LEWINSKY was 

making regular appearances on weekends at the Oval Office. Some 

officers working the Oval Office Detail would say, "Your girl 

came here again." An officer senior to FOX said to him "There's 

something you might want to know" and the officer, GARY BYRNE, 

related that he had told a White House staff member that LEWINSKY 

was making a lot of trips to the Oval Office. Very soon 

thereafter, BYRNE was apparently called at home by EVELYN 

LIEBERMAN who wanted to talk to him right away. BYRNE agreed to 

meet with her at the beginning of his next regular shift and 

advised her of. his observations. Within a week FOX saw MONICA 

with tears in her eyes in the hallway, and she said, "I don't 

work here anymore, I'm going to the Pentagon." 

FOX saw LEWINSKY at the Oval Office or with the 

President on these three occasions. FOX cannot recall the dates 

of these sightings, and his personal diaries do not have 

notations of these events. The diaries for 1995 and 1996 do 

indicate the dates and hours that FOX worked. The scheduling 

department of the Secret Service at the White House would reflect 

the names of fellow workers on shift with FOX. MONICA did not 

have any real confidants or friends that FOX was aware of, as she 

was usually -alone. FOX never observed any physical contact 

between MONICA and the President. 

FOX observed HILLARY RODHAM CLINTON come to the Oval 

Office about three times, but she did not stay long. NANCY Last 

Name Unknown (LNU) controlled the flow and timing of the visitors 

to the Oval Office. 

. 

BETTY CURRIE was always friendly, but did 

not visit with FOX until his final return before retirement. 
1174 

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

29D-OIC-LR-35063 

ConcinuationofOIC-3020f LEWIS C. FOX , On 2/6/98 *page 2 

FOX stated that the only person who would enter the 

Oval Office unannounced when the President was there would be the 

steward. This would occur because the President had requested 

coffee or something from the kitchen. 

into the study behind the Oval Office, 

FOX had occasion to go 

as this was a function of 

the guards before the President arrived at the office. The 

officers would inspect the room to insure that nothing had been 

disturbed. Sometimes they entered after the President departed 

to turn out the lights. The study contained a small sofa similar 

to a love seat, a small stand, and possibly a bookcase. FOX did 

not know for what purpose the President used the study, but some 

past Presidents took rest breaks there. 

FOX recently learned of a story, from the media, that 

the President had been caught in a compromising position in the 

theater by a staff member. FOX had never heard this story and 

did not know if it had any validity. 

The President only went into the theater to practice 

speeches or to watch movies. FOX never heard other Secret 

Service employees discuss any incident occurring in the 

projection room of the theater. Access to the theater would 

always be observed by at least one, and possibly two, of the 

guard force. 
1175 

Lewis Fox, 2/17/98 

Grand Jury 

Page 1 to Page 77 

CONDENSED TRANSCRIPT 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 
1176 

Page 1 

Lewis Fox, 2117/96 x1*x,,, 

Page 5 

;1 UNITED STATE DISTRICT COURT 

FOR THE DISTRI 8 T OF COLUMBIA 

:I;_____ _______ ___-x 

:3: IN RE- : 

!<’ GRAND JURY PROCEEDINGS : 

is: 

iE. 

I~ ______--_____-m-x 

is: Grand Jury Room No 4 

i3. Unrted States Drstnct Court I. *- -All for the Dstrict of Columbra 

_A.. 3rd 8 Constrtutron, N.W. 

.-. 

j 

$ij 

.Ir,i g 117. 

.- ! ;19. 

::9‘ 

;:o: 

!?:I 

(22: 

!23: 

:24: 

!?S: 

Page 2 

on 

il! 

[z!whereuDOn. 

LEWIS C. FOX 

i:iwas called as a witness and, having been first duty sworn b 

151 the Foreperson of the Grand Jury, was examined and testr Ty ted 

i~ias follows. 

7. EXAMINATION 

BY MR. BITTMAN: 

:s:Division. 3’ --. Q 

_I-, 

-“, A 

How long were you with the Secret Servrce? 

Twenty-seven years and three months. 

^. Q Let me advise ou of certarn nghts and obligations 

:z;you have You are appearing r, ere today before thus grand 

as a wetness. You do, however, have certarn 

3‘%iga:rons. ’

You have an obligation to tell the truth. If you 

Page 4 

e or rntentionally mislead this grand ju 

2rV 

you may be 

Jrosecuted for that. Do you understan that? 

1: A Yes, sir, fdo. 

Q You also understand you have a right to have an 

j: i attorney present with you today outside the grand ury room, 

i; j and you may consult with that attorney at reasona b le times. 

!;! Do you undent;;: tiiF.t? 

[B: A 

[“: Q Do you have an attorney with you today’ 

Yes, sir, Mr. Mike Leibig. 

How do you spell. his last name? 

Make sure tf its right.. (Examrnrng) Its ’

As a member of the Secret Service, you and 

A Yes. 

Q Okay. This office - I and others from my office 

Yes, thats ’ correct. 

: . : Thats ’ your understanding as well? 

_,I A Yes, sir. 

.I’ Q Okay. So 

j I:! techniques of the Secret S! 

lease do not reveal any protechve 

ervrce. and this would Include any 

: 13: armaments or other thongs of that nature. Do you understand 

..d:that? 

_- , A Yes. srr. 

:I61 Q Okay. You worked for the Secret Service for 27- 

::T]and+ome ears 

.I91 x 

ii?: 0 

Twenty-seven years, three months. 

Twenty-seven years, three months. What did you do 

.: o I for the Secret Service’ 

;_. ; A Well I was an officer - I was a tratnin 

:s;which ‘ the new recruits would come rn. I would grve t 8 

officer, 

em 

1:x] three weeks of undivided attention as far as training of the 

cr 4 1 White House area, agarn - or the alarm systems, how to get 

rzslpeople into the burldings. 

Page 6 

:I! And these would be anywhere from 12 to 15 eo le 

[ 2 1 that would be my group of people Id ’ be working wit .E fhey 

(3]would sta 

1 Ila week o Y 

with me from the time that they came on. Id ’ work 

day work with them, a week of afternoon. .and then 

1 s]- then they would be turned over to the midnight trainrng 

r6]ofhcer. 

I71 So then I would come back and take mrdni ht 

: 8 1 training people that had worked midnr 

9 

9, 

j e]under my wrng and take them around 

hts and bring t em 

he White House complex. 

7 ‘ slexplainin the o 

;:>,are run a?the&?te House. 

ration of the White House and how thmgs 

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

II-1 I also was an advance officer, which would deal 

i I;jwith the metal detectors for protection of the president. I 

: I 3 1 traveled to Australia, Srngapore. and Ja an with Presrdent 

: 151 Bush. I was in Canada wrth President Fp eagan. I was m 

:~ilAustria -or Australia - not Australia, but Brasilia, 

:: 7 1 Brasilia and countries like that with other presidents. 

::9j Agarn. my res 

:iglthe a ents in charge. 

:?o]presi!ent was 

T i! 

onsibility was to go out, meet with 

ey would give me an area where the 

oing to be. Our job was to set up the metal 

;: I ]detectors. mee 9 the officers that were coming in on military 

.L~I ‘ lanes or commercral planes, et them to their hotels, get 

::3] P hem in their rooms, transport w em to and from the sites, 

~24 land then take them - when the detail ended, take them back 

;zj]to the plane, and then Id ’ tie up any loose ends that was in 

Page 7 

[I] the event and go there. 

Also I drd the Pope when he was in L.A. Coliseum, 

jz!which ,_ ,_____ -.. was ..-- a _ bib _;= detarl. __._(, so __ - 

Basrcallv. I ve traveled 

i :idetectons, trai 

Q 

15 j enforcement a encyo 

A ? will say that the 1 

1 zi talking about Uniformed Division, is a l&%r%%mknt [ lo]division. The have the tame nnwer ir +L nir*rirJ ** 

[ 1 I 1 Columbia as r he Metro1 

112 1 have the same arrest 

ii 7, The Secret g 

the country, 

ning; and stuff like that. 

doing metal 

Am I correct that the Secret Service is a law 

Uniformed Division and were ’

_ ______.__. ..I LI3.z YlJLlIb. “S 

oolitan $olice, the Park Police. They 

Owen. 

,ervica itself I would not basically say _. 

i ;; jthat they are a law enforcement. I neyre ’ more of a _ _ 

[ lsrprotective type dealing with, a ain. 

[ 16lpresident. again, everybody w 9, 

the president. vice 

os ’ counterfertrng. They come 

[ 171under the Treasury Department. And theyre ’ not really out 

[ls]there fighting crime, such as could happen rn the Unrformed 

r .--. 191 Division. 

1201 Q 

[Z1]27 years? 

Have you always worked at the White House in your 

1221 A 

[231 Q 

Twenty-seven years, yes. 

Have you ever made any arrests? 

1241 A Yes. 

[?51 Q How many? 

OlC-starr Page 1 to Page 7 
1177 

q __.. .+t. 

1: 

Lewis Fox, 2/17/98 ~. 

Page 8 

A Well, probably no more than five. No more than 

xuAxr21 

Page 11 

: :duty dunng that period of hme was in the ellrpse area 

- 1 obvious!y not in the Whrte House. 

:: I however dunng the 

Would 

g 

ou have occasion 

-1:1996tow;*rnthe &e 

nod now of June 1 95 through Aprtl of 

est Wrng? 

'=I \Zi Yes. 

Q When would that come about7 

iii 

A Well. this would be on the weekends when the 

I?! ? 

ermanent offcers were off or they decided they drdnt ’ want 

o work their da s off. I would be assrgned In that area 

::;; Q 

-. . ! --I A 

&rd would this be in a fill-in type - 

2 

Yes, definitely a fill-in. 

.--! ve;uld you get overtime for working those weeke 

,:lfive 

?: ‘

4. 

Q Have you ever testified In court? 

A Ive ’ been called but never testrfied because the 

:j:case was dropped. 

6‘ ‘ Q Okay. 

.7: (Grand Jury Exhibit No. LF-1 was 

.:, 

,m, marked for identification.) 

i‘’ BY MR. BITT-MAN. 

1::‘ Q Let me show you whats ’ been marked as a grand 

r :I ;exh.c,t Its ’ marked as LF-1. It was previous1 LP-I. 

i ;::Everyone. ! understand, has therr own copy o r that. 

!:31 I p handinagu a red pen to mark the exhrbrt Do 

: 14 lyou recognize the ex I it? 

:5: ‘ A Yes, ldo. 

i:fi; AQ What is it? 

It is an outline of the West Win 

1 i:iHousa press area. swrmmrng pool. I cant ’ ma 3, 

of the Whrte 

e out-this 

I ~91is krnd of blurry here. Im ’ not sure what - on the bottom 

i?3jhere what - . 

121; Q The bottom right - 

Ill ’ A Yeah, I cant ’ - rts ’ blurry - 

113: Q 

A 

where it says something Terrace? 

Terrace. That would be on top of the West Wang. 

igZ;press area, former pool area 

Page 9 

!I! Q 

: ?! House? 

Are you familiar with the West Wing of the White 

:3: A For 27 ears I was familiar with it. 

141 Q Okay. Y s this an accurate diagram? Does it appear 

isjto be an accurate diagram? 

!61 A Yes, it appears to be an accurate diagram, except 

;7 ;the room numbers - I could tell you what was in the rooms. 

:s!but as stated on here, the room numbers are not famrlrar wrth 

:g:me I could tell you the offices. I never knew them as Room 

; :o; 117. 118. I knew them as basically another - an office. 

Q You continued to be a uniformed officer in the 

: $ jSec_t Service during President Clintons ’ presidency; is that 

-:3lcorrect? 

::4: A Tha+- ‘ rnrrnrt 

..C. Q Ok: 

-!s:dunng President Clintons ’ PI 

.i;j A Well. we can 

: 7: because at one time durina his first - first time 

ay. How often would you be in the West Wing 

residency? 

talky about_- I wa”, t:,;zsquite a brt 

:!i~unassigned. so I was at thg mercy of the ass& inments ~~ office. 

:o!whicn. ‘ If thev needed me there, theyd ’ put me in the West 

-::iWrng . 

. 

.,q. It was a basic - I was unassigned Monda 

I_? i Friday. so I was - I was -ust plugged in anywhere. fy 

through 

was a 

.:.r :uhlrty player. As many o t you mtght know in a baseball or 

-:ssomething ’ like that, special teams player, I would be just 

Page 10 

: I 1 plugged in wherever theres ’ a vacancy. Because of m 

~2 1 senmty. a lot of ttmes I would be put into the West 

131 Q 

A 

Did you have a regular ass1 nment? 

Wi%g. 

Well, m regular assignmen 9 - I had a regular 

i:{assrgnment through a Y rme where it was Monday through Friday, 

: 6; and then I 

9 

ot bumped out of that, went back to an unassigned 

;-assgnmen ‘ , where, again, I was at the mercy of the 

i:i!thern out, r,know. 

R BITTMAN; Please note for the record Mr. Binhak 

; ii; has reentere+h;, g;ra#Axroom. 

(251 Q Would you have occasion -you said your normal 

Page 8 to Page 13 

nds.7 

-2, 

:::: a &ut how man times between June 95 ‘ and Aprrl of 

;:j196 ’ did yo%wOrk weekends In t x e West Wmg? 3 ;, At least 15 - 15 to 20. I mean. we could sav 15 

:i7 ;to 20 that - or maybe more. 

: 13 iwork. work. 

My work book only shows work 

It doesnt ’ grve the assignment exactly where I 

::srworked. so I cannot really pinpoint an exact number. 

.:!I1 But I think we - as we discussed, that from the 

::litime - 

:22! 0 June 95 ‘ through April 96. ‘

;231 A 

[241 Q 

I would say 15 or more trmes. approximately 

Okay. Lets go to the map, please - 

!?51 A Okay. 

Page 12 

Q - LF-1. As you can see theres ’ some handwriting 

f i j on the map on the dra 

;;~see Walkway No 1. w 

ram. There IS Walkwa 

l? rch IS to the left of the &I 

N,p&;=yey?ou 

i4i A- Yes. 

(51 Q And then theres ’ Walkway No. 2. which IS in front 

! ;; of one of the doors to the Oval Office at about 1 I :OOT 

ifll 

A Yes, srr. 

Q 

io,Nn 1 

And going now to the right, you have Receptron Area 

L,,.__. 

;131 A Yes. 

!I11 Q And the desk idenbfied as “BC.” whrch would be 

:iz]Betty Currie? 

“.- 3i A Thats ’ correct. 

::41 Q Would you aka s - in these times that you worked 

::slon the weekends in the West I&g. these 10 to 20 times you 

;6lworked ‘ there on a weekends between June 95 ‘ and April 96, 

1 I7 1 where wouAd you be stationed? 

Okay. If the president was not in the Oval Office, 

itgjl would be statroned at Walkway No. 2 by - in that area. 

,i_lThat would be the ost assignment, Walkway 2. which is in 

:::]front of the Oval &ice 

.-q %__I Q 

A 

Okay. When hes ’ not in the Oval Dftice~ 

i31 ’ When hes ’ not in the Oval Offroe. okay, this would 

124 1 be - Monday throu h Frida 

.4 \ 

I would be down In the vrcinit 

;z 5 1 of Walkway 1, whit would e - as you see, the Rooseve r t 

Page 13 

! 1 )Room and C. I would be in that area from Walkway 1 - 

Again. I wouldnt ’ stand there all the time because 

ifiit was like - okay you could move a little bit go down to 

[ 4! the pantry and get a cu 

: j 1 cetera, youd ’ be offe 

of water or a cup of coffee, et 

reZa CT of coffee. 

So that would be 

;,6jwould be in that area. 

unng Monday through Friday, you 

i3! Q Now, I thought you said that your regular 

:slassignment was at the ellipse. 

A Thats ’ correct. But again Monday through Friday, 

lrP;if a Uniformed Division officer wasthere, ’ this was where he 

;;zrwould be. okay? 

ii3j 

2 ?tt% where he would be at that point. Or if I 

~::~worked overtime, would happen to catch that assignment - 

1 I6 1 like if they would ask me to work four hours over and I had 

[ 17 1 this assignment. and the president was in the Oval Qftice. I 

;:s]would be in Walkway 1 area. 

[ISI Q ,Okay. You, testified that you worked weekends 

r2olbetween JTe 95 and Apnl 96 approximately 10 to 20 times. 

!I!11 In the West Wing assignment. 

!??I Q 

:231 A 

tn the West Wing assignment. 

Yes. 

[241 Q How many of those occasions did you work on Walkwa 

rz5)No. l? 

____ 

OlCStarr 
_. 

1178 

BSA Lewis Fox, 2l17198 M[(JI 

Page ?4 

It would have to be between 10 and 20 times. 

Paae 15 

[sJwould be se 

[61 QccImIK~” 

[71 A 

[El Q 

Yes, would be the second person to go.? 

t91No. l? 

Would there always then be two people in Walkway 

I2li A 

I.321 

t231 AQ 

(241 

[251 

- . ..-.. 

And then Echo 6-A leaves - 

And Echo 6 comes back. 

Echo 6 comes back. 

Right. 

Ill Q 

I:lagain - A 

[II 

JSI . 

ts1 ii 

171 A 

Page 16 

Okay. -_ leaves 

isi Q zzi 

r9Jactually be in me naliway. 

A No, you would be in - you would be there1131 

1141 Excuse me. 

t151 A 

y. 

Q 

Its ’ a complicated s 

111 ’ get thii ewantually. 

tern. 

1161 Well, for someone lys Ike me. perhaps. 

I171 A Okay. 

Q 

~:&~eQvalQffice. Thedoorat ll:WLets ’ return to the map, LF-1, and especially to 

I201 

t21J Aa Okay. 

A 

- IS that door normally open or closed? 

$iDVal Oftice. the door is always secured. 

Okay. During - at the time the presidents ’ in tt, ‘

I241 Q Secured, meaning what? 

1251 A Locked. 

Page 17 

I11 Q Wholocksit~ 

A Well again its ’ - when the president comes to 

I : 1 the Oval ClfKce.. he; ’ surrounded by the Secret Service. 

(4JTheres ’ the lead a 

ISJthe president wou l% 

ent on the detail would come in, and as 

come in the Oval Ofhce he would be the 

I ~Jperson that would mme through the Oval Office, physical 

r7Jwalk thmuah the Oval Office. and as coon as the presiden ? 

isJWaS in the&al Office, he would pull the door shut. 

191 _ Q And its ’ locked. cioi - 

1111 

A Its ’ locked. 

Q What about the doors in the hallway to Walkway No. 

(121 l? 

A 

i::ithe one door is the dinin 

The doors in the hallway to Walkway No. 17 Okay, 

area. That is abo a locked door. 

( 15 1 Okay. The other door, w Ii I&I would be the 

r 16 1 of course. Jf the stewards ’ there. its ’ ooen. P 

antry door, ls - 

f hes ’ not 

ii?jthere. itsbcked. ’

~. 

0 

tZipresident is in the Oval Office? 

How often does the steward go in and out whiJe the 

A 

i:!ithere that the steward would - if the preslden 

Well, I can tell you from my ex 

p” 

nences being 

[zzJsomething. the 

wanted 

r23~was coffee, s odp 

resident would buzz the steward. Whether it 

a. or maybe lunch arrangements or something 

[24 J llke that. the Steward Would - the Steward would han 

frsJin that area most generally all the time that the pres if! 

- be 

ent 

Page 18 

[ 1 JWaS in there. with the exception of when he went down to the 

[z~stafl mess to 

resident mlg .I! 

et lunch or get - 

t want for lunch. 

ou know, whatever the 

t3J 

g 

r; 

ack. 

e would go down. bring it 

trJ prepare it right in the little - a Mtle pantry area 

There appears to be a door between Walkway No. 1 

[2lJthe halkva 5. 

X .- 

[Zimean. youre ’ still in a secure mood protedie mode. Its ’

Well, its - I would not say youre ’ freer. I 

(34 JjUSt that you know that-that were’ not ’ - see, I dont ’

tzsJwant to say this. 

Page 19 

Youd ’ say that its ’ not freer its ’ just ma 

I: i a notch above being a little loose: then to go 

p just 

;:;tothe, you knowown and talk 

Q And that I su~oose is because there are fewer 

r5 I -la around. . . 

.-,r--r - - -- --- 

161 A Fewer people. thats ’ correct 

VI 0 

I81 

okay. Do you know Monica Lewinsky? 

A Yes. I do. 

191 Q How do you know he0 

j~~jWestBasementoftbeWhite ousemtbesummer-orin-tt 

A Well.Ksabn~story..so-Iwasworkinghtha 

I iz I Was in the summer, and, again, I was working overtime on that 

rl3ldav,andIwasatthe~ntrolDostanditwasrnthe 

il4 jaf&moon. 

i23jView.’ I Sa 5, “YOU ’ can took at the pi&r&= - 

So m 

i::ipictures and - so then they kindof ’ walk back down, and as 

omca makes the call and they look at the 

OK-Starr Page f 4 to Page 19 
1179 

Lewis Fox. 2/l 7198 XMAX(4) 

Page 20 Page 23 

: ‘ the ‘ re ‘ standing :here. another Whrte House -- okay. Its ’ a 

.^ - s r; e actually worked for the DNC. Her name was Susan 

{3 ._ Levrne. and she had a White House pass, and it was an OGA 

::-pass. whrch means Other Government Agencies, but she had 

; 5 -access to the Whrte House. 1 F> And her and Monica, they kind of ran into each 

r- other, and Susan says -they Introduced themselves, et 

; zcetera, ’ to the fnend and all that. And Susan says to 

: ?.Monica. “Look. Im ’ gotn to give a White House tour here.” 

1:: She sa 

r. ’ .looks a :::.,,,h 1s r 

s. “Would you II % e your friend to go?” So Monrca 

her friend, they kind of look, and she says, Well, ‘

r_L_,“-..‘ 

::3: So the fnend takes off with Susan, 

9 

oes on the 

. ‘ ;. tour So Monicas ’ standing there, and I te I her, “If youd ’

::.lrke ‘ to sit down over here to mv naht and wart for your 

’ -II _ _ 

!:5:papers 

So at this time we formally became introduced as, 

: f 9, “Im ’ Officer Fox. They call me Lew,” and she told mt4hat 

1: jher ’ name is Momca Lewrnsky So thats ’ - after ail this;, 

[ 2: we‘ re ’ introduced to each other. 

[Z1. So were ’ sitting there and were ’ just talking. I 

rzz:asked her where she was from. She says Calrfornra And she 

!z3,sard that - I said. Well, where drd you go to school? And 

(2; -she says, “I went to Lewis 8 Clark. I sard, “Oh, in 

;25:Oregon?” She says, “Yes.” She says, “How do you know about 

.~.~_~~.__ ~~~_ .~~~~_. ~~~~ 

Pa& 21 

c ::that?” I sa s. Web. I follow some, you know, sports, 

:z:watching, Ey SPN. Lewis 8 Clark College, et cetera, and I do 

;j.know its ’ rn Oregon. 

So by thus ttme the pa 

.! Isays. “You dont ’ mind if I sit e, 

en had came down, so she 

ere and wait on my friend?” 

i;.And I says, Well, ‘ you can sit here, but,” I says, “Susan 

.-: Ives a long tour. so ou could be here for a wh(le.” And at 

.“:&at time she says & ‘ ell. not much is going on In my office 

:G:right now. Ill ’ just - Ill ’ ust ‘ sit here.” 

.-,_ So. agarn. we ta I ked. I told her where I was from. 

11:: And so then the vice president came down the 

(1:’ hallway, and I knew he was comin so I just kind of - I 

(:x-said to her, I said. The ‘ vtce press 8% ents ’ coming,” and I 

out of respect for the office. and so I 

ou know, the vice president walks by, and he 

,. - So, again, the schedule - I knew that the 

: 13. president was gomg across the street to the Old Executive 

::j:Ofhce Building. I thank it was Room 450. for a speech. I.. 

:I: -then I 

So It was just small talk between her and I. So 

et the signal that the presrdents ’ coming. So. 

!:I-aaatn. 7 stand up. and I say to her, I sard, “The presidents ’

o she stands up. The president walks by, and, 

i?s-again, same roubne, is a nod, and he goes across the street 

Page 22 

:: to Room 450 in the Old ExecutiveOffrce ’ Building. 

;_: So after about 20. 25 minutes, the president comes 

1:: back across the street into the West Basement, and, agarn. I 

[I :stand up. There were two guests sitting on the couch In 

: 5:front of me, and I think that-the best of my knowleoge. 

[E -they were waibng for Mack McLarty to - for an appointment 

I-:with him. 

:3- So the prestdent walks in, and he Immediately goes 

is-to these two people and they shake hands, and the White House 

r:?:photo ra her is behind him, and he takes pictures of the 

1;: ; press .B en P 

11z:visitors. 

shaking hands wrth the two guests that were there, 

113‘ Then he turns and - Ill ’ say -well, I call her 

: ia:Monica - Ms. Lewinsky was standin 

sin. R 

again to my ri ht. The 

115: 

P 

resident then turned and walked to onrca. shook ands. they 

[14‘ umed. and a picture was taken with the president and Monica 

[ ~7: in the West Basement just, say, from here to that wall right 

113 : there from me. 

[La: And the president then oes back to the Oval 

r:;:Office And, ou know, she was II 1 e, “Oh, my goodness, I got 

[ 2:: my 

rzz.if rt I? 

icture ta z en wrth the president.” She says, “You know, 

adnt ’ been for me sitbng here talking to 

I-?.wouldnt ’ have seen the vice oresident. I woudnr t ’ have seen 

ou, I 

;:;,thepresident and all. I ot my picturetaken. ’ ” 

15: ’ And I said, Well, ?.A onrca.” I said, “you know you 

Page 20 to Page 25 

:-can get a copy of that 

1 

icture.” 

-~todays ’ date and the p 

I sa!d “All you need IS 

otographefs name. ’ And I sard. 

.;“Submit a memo to the photo ofhce and,” I sard. “theyll ’

et you a copy.” And I said “If you know anybody 

et It autographed ” 

ed me ve 

-.to me, “You lrke chocolates?” X 

good She sa s -she says 

nd I said, Wel, ‘ 7-e I sard. 

: >“evervbodv likes chocolates ” 

lhrs time withrn the tme Susan and her 

1: >frtend came 

more about it 

.-I ‘ I mean, she was still in the Intern status But. 

:z 5 f a ain. post to post observation is a common thing rn the 

-:;id. hate House as far as people oing from point A to point B 

::5: And - so Monica wa 9 ks up the steps, and I say, 

Page 24 

You mentioned a cou 

:i lion. The I pass, the intern pass 

.-q, A Okay. Thats ’ an intern pass. The “I” stands for 

.?;;“intern.” okay? They have access - basically,, it WIII say 

::-11 in the computer - if you put their name in. It wrll say, 

.: :i”EOB Access Only,’ which “EOB” means Old Executive Office 

Page 25 

or it will say, “EOB and White House, East Wing and 

that person showed up at your assignment, say 

4 ‘ 1: say if she would show up in the West Basement, or any 

j ?] intern that would show up in the West Basement and say, “Im ’

c1 hens to work today,” you would take a - you would take therr 

7 ‘ I identification. vou would out it in the cornouter. and it 

;; jwould tell youthat - I would ust ‘ use a name, sa Joe 

alSmith ,~ IS authorued to be In t c, e West Wina. and Yl he offtce 

.:,)lthat he-is~assigr-.’ - ‘

_ 

IN L”. 

iI3jtt 

::s]East\i 

::01 

-zllthe W 

,e East Win ’ it would have to definitely say West Wing or 

Ving of?he White House. 

p=, \I?n,Ioes an I pass ever get you authonty to go into to 

-“’ A‘ ”‘“Yes. it aives vou authontv to come there. You 

ou~can~h&e%jp&< bean intern andwork in the 

But vou have to be rn the svstem to aet in there. 

-zslwhich wodd say west Wing, East Wing: et cetera. ’

OlCStari 
1180 

-_. Lewis Fox. 2117199 XHI.5i ‘

Page 26 

Q Can you te I from the face of an I pass whether or 

:snot ’ you have access to me West Wing wrthout going info the 

compute0 

A No You have to go into the computer The 

evetythrng. 

; G 1 her I pass ib get &to the West Wing 

you know whethe;Ms. Lewinsky had access wrth 

!3, A Only n someone - or iy if someone would have come 

;sidown and escort her to & %&. She would have to be 

:?:escorted ‘ She just wouldnt ’ be allowed to walk in 

Q Ok; IY. Grven your first meeting of Ms. Lewinsky. 

j ii j did you see her after that? - 

!:j: A Yes. I would see her occasionally. It woukd be 

11 a.like - II would be kke seerno vour nerohbor. You mlaht SW 

HO or thr% days. Then all of a s<dden 

Page 27 

~1; know, I would see her, and I - this one particular day I saw 

[:her. ‘ and I said, “Oh, hi. How are you dorng?” She stood, 

1: !I” the zast Win?.* ‘ pnd I sad. “Oh, congratulabons 

~3!she sa s. “Ive ’ landed a position wrth a congresston$;;! 

[sIthen I told her, sard. Theres ’ a lot of work In that 

!6;off1ca over there.” And she said, Well, ‘ that+ what I 

[ 1 j hear.” She says, “Thats ’ what Im ’ here for, IS to work.” 

And she stated - at that time she said, “Im ’

!t;down and getting m 

! ii; have been a White ?I 

prcture taken for my pass “w ?I 

oing 

cch would 

ouse temporary pass, which would give her 

! I: 1 access to - she would not have to be waved into the complex. 

II-1 

; I;; otten a 

Q How lona was It after she told you that she had. 

; 14: 9 irst met IT 

ermanent job-& the White House was it since you 

:j‘ ’ 

2 approxlmatelyo 

You know as far as the time. its ’ really hard to 

: 16:say. because she really 

-:~iwould say maybe a mon il 

at a permanent pass really quick I 

:~ithat 

month-and-a;half, something like 

Im ’ sure that she drd not finish her Internship 

13: ‘ You know, the mternshlp general1 comes there llke 

:g:- ‘ I think its ’ probably three months or som.e r- hmg l$e that. 

-2:jand she may have been at the end of her internshi But what 

.::;stnkes me was that Id ’ never seen an intern come P here and 

:?i:end up getting a - in my hme. you know, Ive ’ never seen an 

:24:1ntem get a permanent posrtton there so quack. 

.,q. .-A. Q When do you think this first meeting with her was, 

Page 28 

r~lwhen she was an intern? 

I?/-, ’ A It would have had to have been in the summer of 

r3195. ’

Id.-, ‘ Q Then at some time after that she told YOU she got a 

rslpermanent position. 

A Right. This was - it wasnt ’ - you know, Id ’

i:jsay - I dont ’ really think she finished her internship or 

tslwhatever. I mean, she was looking for a permanent position, 

[ 3 1 I think. when she came there. 

,lCl Q 

iili 

Did you later see her with this permanent pass? 

A Yes.. 

Cl21 Q Do you know what pass she got? 

!I31 A It was a White House tempora 

r 14 1 have been a pass - it would be black-and-whr 7 e, not a - and 

pass, which would 

~~s~woutd have an expiration date on it. 

IlE! Q 

A 

And that would get her into the West Wing? 

,171 That woutd set her anvwhere in the White House that 

;;a ishe wanted to go within, Y&I know, security reasons. She 

[ 19 !wouldnt ’ be allowed to go to the north rounds or south 

[calgrounds to take ictures and stuff like 

i?lj Q &hat is a blue pass? 

9 hat. 

I;:; 

A 

(241 kill 

A blue pass - okay, a blue gass with the colored 

icture means rts ’ a permanent pass, okay. And thats ’ a 

de House pass 

[751 Q And that will get you anywhere in the Whrte House. 

OlCStarr 

Page 29 

, A Yes. 

Q 

: :: knowledge? 

Did Ms. Lewmsky ever have a blue pass, to yc_- 

:: A She had a blue pass with a black-and-white 

Page 30 

[I 1 of. Youd ’ have to go in there and 

And I would see her in t 

ick up the burn bags. 

iiiwas. a 

t e East Wing office, and it 

: .I ltwo or P 

ain. like seeing your nei hbon. You might see them 

hree times, then you mig -9, t not see them for a while 

rs]So I cant ’ really say the exact amount of times or anythrng 

r 6 1 like that 

iii 

Q 

A 

Did you have a cordtal relationshrp with her? 

It was a “Hi, Monica,” “Hi. Lew” type thing. That 

[;q] Q 

[zslweekly basis? 

Would it be farr to say you saw her kke on a 

1 A As number of-yes, probably so. I mean, It muld 

/-i iprobably be - again, I might, you know, see her two or three 

:?j]da 

7 

s in a row, and then the next time I would see her maybe 

:?4!on y one ttme. 

!25; 0 You told us about one time you saw Ms. Lewrnsky go 

Page 31 

[I 1 into the Oval Office. 

121 A Thats ’ correct. 

131 Q 

A 

Can you tell the grand jury about that, please’ 

Iliworking at the 

Oka 

Ova Y 

On this - rt was a weekend day. I was 

Office, and it was a quiet day, and I was 

(61 

171 ? ours out of the West Wing. 

lad the president was over there because it kept the private 

F zi bnn 

Again, on the weekends the staff members would 

1 io,the i 

in guests to show the Oval Office the Cabinet Room 

oosevett Room, pictures and like ihat. so I was kind df 

1111 

? 

lad the president was there that day because there was no 

1121 ours. 

And I came on the assi 

i::ivery long, and I was stationed in t 

nment. 

3, 

I hadnt ’ been there 

e Walkway 2 area, off to 

[ tslthe - I would be facing the Oval Dftice door, and I was 

1 Islstationed off to the - actually, off to the right, just 

117lchatting w;;;%i ent. 

%v al Office door was up and the President 

i :89iof the United States came out, and he askid me, he says. 

[2o]“Have tou seen any ypun 

[xltoday? I said, “No. sir. ” ?te sard Well Im ’ expecting 

congressional staff members here 

[~rjone. He says, Would you please let I& know when they show 

[?31up?” And I sard. “Yes, sir.” 

1241 So the agent was, agarn - he was in Walkway 2. but 

[?SI he was to -would be to my left, okay? Im ’ more down toward 

Page 26 to Page 37 
1181 

Lewis Fox, 2/l 7198 

Page 32 Page 35 

11 IWalkway 1 and hes ’ more back toward Walkway - Of Betty 

[z~Cun-ies ’ office, but still in that area. 

[31 Q Why dont ’ you, Mr. Fox -why dont ’ you identify - 

[41 

Aa Okay. - on the,document -why dont ’ you put an LF‘ ” 

tziwhere you were - 

[71 

I81 Aa Okay. 

[9]0cculTed? 

- and then an “A” where the agent was when this 

1101 

1111 

(l&e witness marked the document.) 

E WITNESS Okay, thats ’ approximate. 

I121 BY MR. BI-l-lMAN: 

Q Okay. So, just for the record, the agent was in 

~~~~~~.!iT%%&ing Area No. 1. 

approximately in the doorway between Walkway 

1161 A Yes. yes. 

~:&m?. 

Q And you were right outside the door to the Oval 

A Correct, but to the right, rhore - to the right of 

i$ithe door, okay? 

I211 0 Well, on the document, to the Left of the door. 

1221 A Oka , okay. 

1231 Q To t;e right facing the door - 

1241 

[251 A0 Yes. -from the hallway. 

Q 

Kiup, I assume. 

Was the agent at the rope line - the rope was not 

1251 A No, sir. no. 

Page 33 

111 A Thats ’ correct. 

0 

i:iit take place? 

Okay. And when was this approximately? When did j 

A Okay. It would have-a 

I:; have taken place between 12:30 and 2: 9 

ain it would have to 

0 that day. 

161 Q Either a Saturdav or a Sundav. 

i7i 

[El 

I91 

IlO1 

A Saturda or Sunday, yes, sir.* 

Q Do you l now what month it occurred in? 

A No, sir. 

Q Do YOU know what time of Year it was? 

illj 

[I21 

1131 

ii4i 

I151 

A I wduld sa 

0 ,p:.” fall o r 

it was late fall. . 

A 

what year? 

Q 95. ‘

A Yes. 

Q Oka 

A The L st of my - mv recolledion of this. 

Cl31 ‘

1171 

I181 Q 

A 

Please continife wh& happened. 

f:zland the aaent come; to ke and savs. 

Okay well the president oes badt in the office, 

d ell. what% aoina on? 

iziil says, V7i 

[zzland see if Im ’ righ 

1231 So I descrit 

41.” I sa,y?, “let me desuid the p&son to-you- 

.~~. i&d Ms. Lewinsky. without mentionin the 

124 iname? in detail, dark hair - you know, I gave a genera B 

[z51descnption of what she looked like. 

Page 34 

ill 

121 

[31 

I41 

Q Physical description. 

A Physical description. And he says, wh. okay.’ 

So within ten minutes or so - 

9 vC_a_n I stop you there? 

I51 . n Te.5. 

Q When you said the agent said something to you to 

176ithe effect of, “Whats ’ going on” - 

A Well, meanm 

iiihad heard the conversation 8 

you know, whos ’ coming. I mean, he 

om the president, saying that he 

[lolwas expecting someone. I mean, he heard the conversation. 

Ill1 Q Dii 

112 Iquestion to you tha r 

ou get the impression from the presidents ’

[1310f people? 

he was expecting one person or a group 

A Hi statement was to me. “Im ’ expecting a young 

i::ilady a oun congressional staff member.okay? ‘ Now he 

tl6ISaid:d oul C? 

Q 

you please let me know when they show ubr 

i:i;physical desai tion - 

Okay. And you tell the agent this and give a 

I191 A physical destiption of Ms. Lewinsky. 

1201 Q 

1211 A 

Okay. And then what happened? 

Well, were ’ standing there, and within a period of 

[ 22 1 ten minutes or less. Ms. Lewinsky shows up canyi 

tz3lmuch. yov know, kke thats ’ on the table here. some 7%’ ng folder of 

[zalthat descnption. And she immediately - she comes to me 

rzsland. again, we exchange “Hi. Monica,” “Hi. Lew.’ and she 

111 

r,, 

Page 36 

AQ $$ty. Was the agent looking into the Oval ORce? 

t-1 

ij 6k 

r : i going into the Oval b 

Do you know whether prior to Ms. Lewinsky 

I 5 I alone or not? 

fice whether the president was in there 

A I would say that he came to the Oval office alone. 

i76;The best of my knowled e he was there alone. 

[RI Q How wou 7, d you know that? 

A Well if somebody would have been in there with 

[:oi ’ him my relief would have told me theres ’ someone in the Oval 

[ll@ffibe. 

[I21 Q And when Ms. Lewinsky went in, do you know whether 

rl31anyone else was In there other than the president and Ms. 

[ i 4 1 Lewinsky? 

1151 A 

1161 Q 

Thats ’ all I saw in the Oval Office. 

Is there any s 

[ 17 1 not there are other people in r 

stem to alert you as to whether or 

[~elpresident? 

he Oval Office with the 

A 

i:i!the onty way I would know is if son-&x& - after the 

Not in the Oval Oflice no theres ’ no system to - 

rzllpresident entered the Oval Office, if somebody came on that 

[zzlday. they would have had to come through the door in Walkway 

[z3]2 or through the Colonnade C. An alarm would have been set 

[nrloff. and that would mean somebody else would have came in. 

I251 0 What if somebody entered from Ms. Cunies ’ area? 

Page 37 

A 

I: i the door was locked. 

That would be - that would be impossible because 

Q So you didnY see an 

I :; Lewinsky rtez;ith;he presiden t! 

one else go in afler Ms. 

[51 

f76;doors 

Q And had someone entered from one of the other two 

[El A Thats ’ correct. 

[91 Q And 

I101 A ry 

ou would have knowti that someone was entering 

Tha s correct. 

Q 

i::iwith the president on that da 7 

Okay. How long was Ms. Lewinsky in the Ovql Oftice 

I::~becauseofthdtimethat-.thetbne 

A Okay. I wou say a roximately40 minutes, 

I8 R$resident came out 

I 1s 1 and .was in Fe Oval Office, he came o and w time Ms. 

1161 Lewlnsky - It was probably 20 minutes into my stand up on 

t 17 I that time. 

1181 Q And then you left? 

1191 A Yes. 

WI Q 

[211 

And by the time you left had Ms. Lewinsky left? 

A .No. 

1221 Q 

(231 

She was still in there by the time you left. 

A Yes, correct. 

I241 Q If the 

[zslwould you know that -e 

resident were to leave the Oval Office, 

Page 32 to Page 37 OlCStarr 
1182 

BSA Lewis Fox. 2117198 XMAX(7) 

Page 38 

A Only if he went through the door in Walkway 2 or if 

-!. he would have exrted C. the colonnade door, I would have 

: 3 : known that. 

.2 Q The door at 3:O0. 

A YM .- 

:< Q ‘ What if thefresrdent were to go into the study 

area, woul; you know that. 

No, I would not know. 

THE FOREPERSON. Excuse me, Mr. Bittman. Its ’ 1 

for the grand urors ‘ to take a ten-minute break. 

MR! BITTMAN: 

THE WITNESS: 

O;;;t,Lets ’ take a ten-minute break 

ltness excused. Witness recalled. 

rv HE FOREPERSON: Mr. Fox, Id ’ I ike to remind you 

that youre ’ still under oath. 

THE WITNESS: Yes, maam. ’ I understand. 

BY MR. BITTMAN: 

Q Mr. Fox, you identified on LF-1 an area in the 

walkwaythat you wrote on, you have two red bars in the 

_--. I- r walkwav? 

,-- 

_--. a A Yes. _^I^. 

.-- Q What do those represent? 

,T:’ 

:I:: 

A Okay, that is the area durin the time that the 

resident would be in the Oval Office that t e Unrformed 

;,;jg9, 

rvrsron officer would be basically required to stay in that 

:il me 

Page 39 

: : : area Monday through Friday, during non;lal business hours, at 

:: : the White House. 

.i. _d. Q What about on weekends? 

;r A Weekends, a little more freer. We could maybe go 

: s i down to the Walkway 2 area, chat with the agent there. 

:- ‘

: I : bars, is th$ 

ir; 

kn~Jl”f:t~&~~n those two red 

ay. Yes, that would be the assignment called 

5 _-. when the presidents in the Oval Office. 

::I k day that you just described for us when Ms. 

::: j Lewinsky came In, went into the Oval Ofice. do you remember 

: :I how she was dressed? 

.l ‘ A Again, I - I think she was wearing a dress, just a 

i I i j normal - nothing elaborate. It was, again. weekend, like 

::z ma be a down - nothing real - you know, not a business type 

._T -. ou tr it or anything like that. I don t know. It was probably 

::-.a dress. 

::i. Q 

A 

Do you remember what pass she had at the time? 

.. i. It would have been -- it would have had to have 

:I: been a temporary White House pass, a black-and-white picture. 

_- Q Do you remember whether Betty Currie was in her 

-!f office ‘ or in the West Wing that day? 

:: A She was not. 

Q Do you remember whether Nancy Hernreich was in the 

./est ‘ Wing that day? 

Page 40 

A She was not. 

Q 

dernreich sit? 

Was anyone in that area where Mrs. Currie and MS 

1: i have 

A That office was secured that day, so no one could 

been in there. / -. 85 :_: 

Q Secured. YOU mean closed and locked? 

A Closed anif locked. 

,c- Q You described the rope line 

! G:Office. that is, the door at the 11:OO area. d 

oing into the Oval 

hat IS the 

. ,’ rope line? What do you mean by a rope line? -a. 3.. 

-- A Okav. It would be when the Oval Office is -when 

j 1: : the presidents ’ not in the Oval Office, okay, theres ’ a rope, 

’ 7. a blue velvet-covered rooe thats ’ out uo there. that if vou 

: ;; : brought friends into the 6vat Office the 

:Isithat area and look into the Oval Otice. 

could walk up to 

: : 6 : from going beyond that ro 

1-I ‘ ‘ Q And thats ’ P Ike a tour situation? 

?he$e restricted 

okay, into the val Office. 

..a: A Yes. It would be staff members brin 

1 iii special guests, et cetera, coming in on the weeken 3 

ing in family, 

s and 

j: 3 :Saturdays after 1 :OO, Sundays an 

: z L : the presidents ’ not in the Oval 0 8’ 

rme. you know, as long as 

ice. 

then walked up to t 

Page 41 

A Thats ’ correct 

Q Is that common7 Is that what the a er:s are 

: supposed to do when someone enters the Oval 0 f? 1ce7 

A Well, 

rotection. so its ’ tha ? 

enerally. its ’ - theyre ’ tramed rea..y for 

they want to see whats ’

P 

oing on 

o that would be a common -- common thing or them :o walk up 

Ii: and see, you know. whats ’ gorng to happen 

Q Is rt common or uncommon for then the president. 

ii after he receives the guest. to tell the agent to - or ask 

:I the agent to shut the door? 

-- A Well, 

11 .something he wante J 

ou know, apparently the presider,! had 

to discuss with Ms. Lewmsky. and he 

: I -wanted to - you know, asked the agent to close the door 

. . _* 0 Is that common or uncommon7 

- thinking that that was the person that the 

__ - 2-president was expectins. 

A Ttiats ’ correct. 

Q Why did you think that that was the person the 

: : : president was ex ecting? 

Page 42 

.^. A 

15 i she became m 

v\p,II after she 

giri. I mean, t 

ave me - after she 

ats ’ police talk or w I! 

ave me candy, 

7 

4 atever, 

: L : thats ’ Lews ’ gtr , you know, hey, Lews ’ girl. 

,_. 

.-. Q Quote, unquote. 

A Quote, unquote. You know, nothing. but rt was - 

; f ; rt became Lews ’ girl and - 

Q 

I>- A 

To whom was she Lews ’ girl? 

To the officers in Ule Wes Wing. the officers that 

it-worked ‘ around there, because they knew the candy - candy- 

: 1 or ‘ did it get back to 

_- -. the president in the 

Page 43 

:: again. ‘ throughout the time up until she left; 

,_: Q Was there any other occasron that you personally 

I : : saw Ms. L;wrnr+keys;n the West Wing? f;f 

.=. 

_-. Q 

8;‘ A 

Can you describe that for us, please? 

Well, again, her bnngrng papers over. her going to 

if i the staff mess to get sodas, et cetera. 

One other time IS. I was comin 

: i; I saw her leave the Oval Office. Again, I 9, 

to the assignment. 

i: i the amount of time she was in there. 

ave no idea of 

I was ust ‘ coming on, 

1: : and she came out the door and proceeded I rom - to the right,, 

:z :which would have been Walkway 2 throu h Waiting Area, all the 

:z:way over to Walking (414, she proceede 8 

-4: 

~I5~office? 

Q 

that way. 

Where were you when you saw her exit the Oval 

[Lb: A Oka 

r:- lof the Oval Office dy 

I would have been down in Walkway 1. in view 

oor. 

Q And where was she? 

A Where was she? She would have been exiting C. 

Walkwav 2. 

D Qkkav. There actuallv are a number of cs ’

A Oka+. the 11:OO. the1 ’ 1 :OO. 

0 The-1 1:00 door. 

A Yes. 

Q Okay. You saw her exit that door? 

olcstarr Page 38 to Page 43 
1183 

BSA 

Page 44 

Lewis Fox, 2/l 7198 

Page 47 

I.. 

.-. A Yes. 

.“. 

1:; hallway? 

Q And then she took a left and proceeded down the 

:A. A She would go to the right, which would have been 

:; 1 Walkway s Wa~~~vNo. 1 - 

i6; ,-> 

.- : I% Oka;. 

I:’ 

. Q 

9: ‘ A 

$4: iy; were coming from the other direction 

. . . ,A.. Q You’ were commg from the left. 

i:;: A Thats ’ correct 

-.?I *l-a Q Okay. Dtd you talk to her on that occasion? 

;131 A No, sir. 

1:;: Q 

( : 5 7 where Ms. 

Do you know when that was relative to the incident 

; : t: : observed? 

Lewinsky went rnto the Oval Offtce that you 

::;. 

::a; 

A 

Q 

Not really. no. sir. 

A 

Do you know whether it was before or after? 

;15; I would say it was probably - probably after. 

“01 Q Can you estimate ivhethei it tias within a couple of 

)! I I months. within a couDle of weeks? j--l 

[--‘I ‘ A Probabl ’ within a~months ’ time. 

[I731 60 

;24joccasion? 

Q Okay. you remember what she was wearing on 

1251 A No, sir, I dont. ’

that 

XMAX!I, 

:: !saw her on that day, and she was -- she was ,eal tea 

r-land I said, “Monea * ‘ you know. “whats ’ the matter7 .-, 

f3;you know, “Youre ’ okay7 

!I gyp 

!4: And, you know. tears were rolling out and she 

:j Isays. Well, 

1 c:the Penta 

you know. “theyre ’ trying to get me a job at 

iv 

on.” She said, “I dont ’ work here anymore ” So I 

;T;said, We , you know. “take care of yourself _ And she 

ralleft. 

So withln a day or so I was talkin 

i 1; Byrne. I said. Well. ‘ 1 guess they shtpped 

?o Officer 

80”1ca out “ He 

; : 1 J kind of give me a little smile and he sa s. “Yeah.” And so 

( 12; he tells me the sto 

r 

that - that he ha J went to Ms. 

[13!Liebermans ’ office o - he was quite concerned about her 

:14!frequent visits to the West Wing, to the Oval Office area -- 

[15j Q 

!16] A 

Officer Byrne was 

Yes, Officer Byrne was. And he went to MS 

::?!Lieberman, and apparently she was not in the off&, so he 

r~elleft his phone number. He said. “Have her ail me tonlght 

:;glwhen” - or, “Have her call me.” 

[2Oj So a 

;2:land it was Iw”. 

arentiy Gary went home, and the phone ran 

s Lieberman, and she said shed ’ llke to talk P, o

I zz 1 hry and shed ’ like for him to come back in to town. And Gary 

rz3lsaid, Well, I live like 40 miles away.” He sald. “And Ive ’

[24jgot plans tonight.” He said, “Ill ’ come in tomorrow.” 

[251 And so apparently he went In the next day after 

Page 45 

Q 

A 

And you were comin 

Thats ’ correct, on to ill 

on to your shift? 

e either E 6 or E 6-A 

I m. A_: A No. 

13! Q Do you know whether the president was in there? 

13: A Yes. 

IS! Q 

15: A 

$$te at least was in there. 

.-1 

. 2 Q Do you know whether anyone else was in there? 

2 ‘

--. A 

;?: Q 

No, not or! that occasion. 

LC: ’ A 

Okay. Is rt fair to say ou just dont ’ remember? 

:ljexlt the - 

That s - bastcally, tha I s tt. I mean, I saw her 

*_)> 

--_ Q 

z3!whos ’ in there. 

Okay. Because, I mean, it is your job to know 

24: A Right. But. again, I think robably what happened 

z5lwas, when I came, the offbr had kind o P turned and seen me 

.- .~ _ ~~. ~__~ ._~__.~ _~~~ 

Page 46 

;ijcomin 

1: 1 walke 8% 

and he was in this area here, and he probably 

- you know, walked away, wanting to get out, you 

13 1 know, take his break. 

il?l Q 

Ii31 A 

vow dodyo~,spell his last name? 

Its San y, 11 s a female. Its ’ V-e-r-n-a. 

ji:iAlmasy - 

The regular assigned guys would have been Bob 

(161 Q How do you s II Bobs ’ last name? 

I171 A A-l-m-a-s-y. r nd another officer would have been 

[ 18;- a ain assi ned at would have seen, would have been Dan 

; 19 1 Or&k&ski ?I-r-d-a:k-o-w-s-k-i. 

l;?jknow, would kind of talk: 

AAd - I mean they was the regularly assigned, you 

i%iseen Ms. 

Q Do you remember Gary Byrne telling you that he had 

Lewinsk go into the Oval Office with the president? 

1241 A We 7 I, this was after the - again, when Ms. 

[ :: s 1 Lewinsky was basically told she was going to the Pentagon, I 

Page 48 

111 that and talked to Ms. Liebennan about what was going on in 

[zlthat srtuation, and within the next day or so, this is when 

[ 31 Ms. Lewinsky was sent off to the Pentagon. 

[4! Q 

f 51 Lieberman? 

What did Officer Byrne tell you he told Ms. 

A 

i76jOff1ce too much, in his opinion. 

That Ms. Lewinsky was hangtng out around the Oval 

I31 Q Is that somethinq that unifo~ officers typicairy 

rsltell White House staffers about, 

conscientious person, 

e had to tell Ms. 

Q 

ii:(office. or did he see Ms. Lewinsky go into the office on 

Did Officer Byrne see Ms. Lewfnsky around the 

i22j Q But Officer Byrne told you it was a couple of days 

[:3! before you had your conversation wtth Ms. Lewinsky about 

!? 4 I being movid. 

{25! Okay. Ms. Lewinsky, again, had, you know, to& me 

-.- -..__- 

Page 49 

[ ~:she was going to the Penta 

[z 1 day or so later I talked to 0 iI 

on, and a couple da 

leer Byrne, I satd. 4 

s$er - a 

[ 31 see Monicas ’ going.” And it was a day - one or twodays ’

, i P _,- I after .- ihat . ..-.. 

1: i that he had made thus talk with Ms. Liebemran the phone &II 

And he stated to me - thats ’ what I stated to you 

r?lw+~nting him to come back in, he said he had dlans with his 

I 9 Iwife and would come in the first thing in the morning and 

[sltalk to her. 

Q 

1: i ; told you that he had seen Ms. Lewinsky around the Oval 

Was that the only occasion where Officer Byrne had 

[lzloffice? 

1131 

(141 Q 

A Yes, ba;;l?. 

A 

Tell us abou the trmes Sandy Vema told you. 

That a 

I::!-- she did not tell n-t& 

aln, was lust - I mean. Im ’ saying those 

hose were people that had worked 

[17]the assignment, that had -that I had heard -again,, had 

[I 8 1 heard that she was there. 

rlslonly officer that actual1 

She never - Gary Byrne Is the 

told me about this. 

I;y;had not 

The other o f? 

TR 

~cers had indicated - you know they 

[zzlthem. 

ersonally told me. That was Ordakowski Aliasy and 

ey were the regular1 

[23]would have more hrgh conta cc 

assigned officers, ;o they 

rz~lwould have had. 

with whats ’ going on than what I 

I-151 Q I thought you testified that there was common taik 

Page 44 to Page 49 0Gstan 
1184 

LISA Lewis Fox. 2/17/98 

Page 50 

! I i amon 

i: out ‘ o P 

the officers that Ms. Lewinsky was seen going in and 

the Oval Office. 

[j: A Thats ’ correct. 

!4’ Q Okay. Was the common talk about the officers, Gary 

: 5 i Byrne, Sandy Verna, Bob Almasv, Dan Ordakowski? 

XMAXISI 

Page 53 

: I 1 reference to a door to whats ’ marked as the Drnmg Room on 

I ! this map. LF-1, and It wasnt ’ clear to me which door you were 

3 1 talkrng about. 

;: So I want to talk about the two doors from Walkway 

: 5~ 1 that enter rnto the Dmmg Room. okay? Are you wrth me7 

[61 A Yes. 

i-j Q 

! 9 1 of the Dinmg 

Okay. First. the one thats ’ marked C. to the left 

Room. 

ia; A Yes. I?i i I 0 And others? 

;3i A Probably so, not - theyre ’ not names that I would 

14: not - would not know. 

;::: Q And you heard this talk. 

[il: A Yeah. ,7^, i--f Q And others heard it. too 

[13i 

iL4: 

A I guess so. 

Q Do vou know Tom Owens? 

:.-: 

c-3, A Iveheard ’ the name. f cannot place a - cannot 

!:i]place a face to the name. I cannot really - he could walk 

: : 7 1 in here and if you show me a picture, I - two or three 

: I 3 j pictures, I might be able to point him out to you. 

:;41 Q These are Secret Service uniformed officers, I 

123 ’ J believe. William Cherry? 

111: A Cher 

li-. a--, Q Mark T 

does not ring a bell. 

rant.zen, F-r-a-n-t-z-e-n? 

Aa %?k%%$%%%?ienderson? 

A Henderson, yes. Either Maurice Henderson - 

Page 51 

!l] Q Whos ’ Maurice Henderson? 

:; ‘ A Maurice Henderson is a Uniformed Division officer, 

[ 3 ja black gentleman. 

[:; Q Do you, know a woman named - who used to work, 

j s 1 actually, w;s M;o-ewmsky s boss, Jocelyn Jolly? 

16: 

i71 0 Drd you ever know that Ms. Jolly was removed from 

: B 1 the White House at the same time that Ms. Lewinsky was? 

!51 A 1 did not know that. 

::a: Q Do you know a gentleman by the name of Carpenter 

: : I ; who was in charge of the protective detail between 1992 and 

[::;1996? 

.:3’ A 

: 14 j Administratton. 

Yes, Dave Carpenter and 1 go back to the Carter 

:15: 

.>;: 

0 Do you know him - is he a friend of yours? 

.A,> A 

Q 

Yes, I would say hes ’ a friend. 

.- : Is he retired? 

.:3j A Im ’ not sure. Im ’ not sure. I know he was 

I 51 transferred off the detail to 1800 G Street. But, agam, I 

:zg 1 know hrs wife, and when I see her I say, “Hey, hows ’ Dave 

I z 11 doing,” you know. 

,.^. ‘

-- ‘ 0 Did his wife used to work at the White House? 

?3’ 

: i anytime 

A Yes. His wife was with the steno raphers, which 

- If there was a statement by the press 2 ent made, it 

?- :would be in the - much like we have here to my left. She 

Page 52 

tould be in makin 

_ :statements and ta 8. 

the statements - or collecting those 

ng them to an office, typing them up, and 

i 31 releasmg them to the news agencies. 

141 Q 

[slshe is? 

Did you ever see Eleanor Mondale? Do you know who 

16! A I do. 

!I ‘ Q Have you ever seen her go into the West Wing? 

181 A No. 

r91 Q Okay. Have you ever known any Secret Service 

[I o j officer to be reprimanded or demoted for tetting people in 

f I 1 I that shouldnt ‘ be let in? 

il2j A Yes, 

L131 Q Durin 

[I41 A Not- 9 

the current presidency, President Clintons? ’

cant ’ recall against - not - I cant ’

115 I recall aaainst his presidencv. 

i16j - Q Oka ’ 

[l-J1 MR. BIT&IAN: Thats ’ all I have. 

l131 BY MR. WISENBERG: 

[19i Q Im ’ oing to go over to this position so I can get 

[zo 1 a look at your map 9 here. 

[2i] A Okay. 

Q 

/%iExhibit t-F-1 over here? 

Were ’ looking at LF-1; is that correct, Mr. Fox? 

A Yes. 

Q Okay. You mentioned earlier a - you made 

!:5: Q. All right. Thats ’ not a door that somebodys ’ just 

;1;;gorng to goAm a{:-walk nght In. typically? 

!I“ 

ii?’ 

I:“; 

Q Very unusual. 

Ix; 

A 

Q 

They have to know how to get in. 

Okay Theres ’ a specral way to get in? 

p; 

A Yes. 

Q 

A 

All right. Do you need a key to get In? 

c:31 You can use a key. 

c:41 BY MR. BII-TMAN: ‘

:751 Q Who has keys? 

Page 54 

Q 

[ii idoor youve ’ identified, the main door into the Dining Room, 

--So a staffer would not typically have a key to this 

[ i 4 i correct? 

Ii51 A They would not have a key. 

[i61 Q 

117 1 without a key? 

All right. Would they know any other way to get in 

113: A No. 

[:9! Q 

l-0: 

Okay. Is there ,a wa to get in without the key? 

L--1 

$ TRlxmygh this - rnto tze dtning area? 

,-:: 

12 ’

[131 

A 

Q 

lfqou look back at the patio - 

A 

No, t meant throu h that door. 

!:4: Oh, through that 8 oor. No, they - I believe they 

;zsjcould not get in. 

Page 55 

ill Q OKay. 

[2! A 

[ 3 I system, okay? 

I mean, it would be - again, its ’ under a secure 

(41 0 And I take it from what youve ’ told us. even if it 

[ 5 I wasnt ’ secure, typically, there is a uniformed 

[ 6 I a view of that door at all times; is that 9 

uard who has 

A Thats ’ correct. 

correct 

[71 

181 Q 

f~~Ofkf3 or not 

Thats ’ correct whether the presidents m the Oval 

_-> -- - --- 

[lOI A Thats ’ right. That door is always locked. 

I111 Q All ht. 

[I21 

$ 

? 

i ::; but whether that 

!$tw~r?tl~~$estion is - p,ve ‘ told us that, 

oor IS locked or not isnt ’ t ere always at 

[ 151 least a uniformed Secret Service person with a view of that 

. r:fildoor? _ _ , - . . 

(171 

I181 

[I91 

1201 

rz~jtheres ’ a 

[?2! 

A Thats ’ correct 

I 

2 

4 

Whether or not the president is in the Oval Dffice. 

Thats ’ correct. 

Z Okay. The other wa to get in - youve ’ mentioned 

patio door into the Dining J 

A Thats ’ correct. 

oom, correct? 

3 ls+t$prcally kept - 

II nght Very unusual for anyone to enter in 

Page 50 to Page 55 
1185 

ESA Lewis Fox, 2/17/98 XMAX(l0) 

Page 56 

:‘tnrough ‘ thr? 

Basically. nobody -- I mean. a 

i: : secunty that no one could actually get back t 9, 

ain. were ’ talkmg 

: 4 : mto that area. 

ere to get 

;5 Q Okay. Then you mentioned the pantry door: whrc? IS 

ii. marked wrth a “PD. 

i--over on the rioht: 

not by you, but its ’ marked wrth a “PD 

is that correct? 

!:I- ’ A Yes. 

i 1 : 

r.: L _- Q Is that correct? 

::; A Yes. 

!I:: Q And youre ’ referring to - 1 want to just make sure 

; : L. what youre ’ referring to when you say that because on the 

: :-: pant door. there are doors from the antry out into Walkway 

I : 3.1 an r from the antry Into the Dining g oom, correct? 

!,-‘‘ 

t-., A Phats ’ correct 

;;:im-, 

I:;. 

II?- L--. 

124:there. 

125: A No. 

. . Q 

ii : the uniformed 

And if the 

uard out Y here IS is watching t 

do, youre ’ watchin 

3, 

them, or whoever 

em, correct? 

._. i2 A Thats ’ correct. 

Q All ri 

ii! of the utmost secun y wrthrn the White House the area were ’

9 ht. Is it fair to say that this is an area 

: E -describrng. that walkway leading into the Dining Room; is 

[ -. that correr 

15‘ Yes. 

! 5 Q Does some kind of a secret alarm go off - if a 

jl;. 

f” ‘

i-son were to open erther one of the - d a person were to 

1::: ry to get into the Dining Room, either through the main door 

!:;- or through the pantry door, does some kind of a silent alarm 

; : 3 : go off that alerts ou 

;:;- MR. Bl?f%?4N: 

uys? 

That gets into a security area. 

--z i-- THE WITNESS: That s in a security question. 

!Lt BY MR. WISENBERG: 

:I-. _A Q Oka 

c-: _-.. A I ustydon ‘ t ’ feel comfortable in answering - I. i :__ Q dkay. .^_. 

-. A - 

i:::question. okay? 

in answerinq - that Question. Thats ’ a security 

,-- : -- Q Okay. If I understand you, when the president is 

: :I in the Oval office on a weekday -, 

.1 . 

, - : A 

i.5 

Monday throu h Fnday. 

0 Okay. nght. 1R hen he s in there, youre ’ going to 

Page 58 

: I :atways have plainclothes Secret Service somewhere ini im Thats ’ correct. 

L;. Q And you will have uniformed in w, in the 

;z.area within the red bars you have drawn. 

A Thats ’ correct. 

[:3‘ Q Where would the uniformed guard be? Within the 

j;;isarne bar area - 

A No. ;irx - or would the uniformed guard move over to 

i: 

j:Zokav? ’

A The unhoped officer would move over to 

would be0 Atl right. And, I take it. that unhoped guard 

Page 56 to Page 61 

Page 59 

;; w;*tvrew all the way down(l(lllQ But youve ’ still got the.plainc%?hes Secret 

::3:Service there. . 

::i: A Thats ’ correct. 

,.;. 

.--. Q Weekends when the president isnt ’ there. the 

[ 16: plainclothes Servtce Servrcemen go away. I._. :A> ’ A Thats ’ correct 

119: 

i : 9 i uniformed 

Q Where would vou tvoicallv be stationed. or the 

erson be stationecj? . - 

1201 bl 

Q 

1 would be.at thwgi”,;tJ-g; gyhrst ’

Okay, all right.. 

1;; 1 time you met Ms. Lewinsky when you were working in the West 

113; Basement in the summer; IS that correct? 

124; A Thats ’ correct 

i25; P That would be the summer of 95; ‘ is that correct? 

Page 60 

I:! A Yes sir. 

0 All n 

/iiCarpenterthat Mr 69 

ht. You mentioned that this fellow 

tttman 

[ 4 1 Mr. Bittman mentioned it. 

mentioned had been transferred,or ‘

1s 1 House detail? 

Do you recall that, from the White 

I63 A Yes. 

171 Q 

A 

Do you know why he was transferred? 

[S! I have no idea. I thought it was a 

[ 91 k&w he got another grade. Its ’ basrcally what I 

romotio~, you 

[:3;lm ’ not sure. 

i eard. 

Ii!; Q All ri 

111; about the transfer, 8 

ht. You havent ’ heard anything unusual 

t at -- 

!:3: A Oh, no, no. 

[I:: Q Okay. You mentioned that the president said - on 

: i 5: the day that Ms. Lewrnsky was in the Oval Office for. at 

1 i 6; least while you were there, about 40 minutes. approximately 

;:? ~40 mmutes, you mentioned that he said that he was wartmg 

[ 1 i! for or expecbn a young congressional staff member? 

i19: A Bhats ’ correct the 

Q Did you interpret t 

IzFiWhite House who was In con 

t; 

re ‘ his words. 

at to mean somebody from the 

122 ;somebody who was from the E 

ressional staffing as op osed to 

P 

[23:Congress? 

ongress, who worked or the 

[2r: A That I -the White House. 

!15: Q Okay. Because, obviously. a congressional 

r : ! staffer - 

Page 61 

i2: Aa Yeah. 

I:ithe West Wing. 

-wouldnt ’ be able to walk freely in the area of 

[5! 

{61 

Aa 

17’ 

Q: ‘

A 

Nckahey would not be allowed access. 

From the Hill. that is. 

;;; 

Q Right. 

BY MR. BITTMAN: 

Q Do you remember, Mr. Fox, the name of the agent who 

I:Eiwas present with you that day when Ms. Lewinsky entered the 

I 12 I Oval Qffice that you saw? 

iI31 A 

[ 14 1 those thin 

Again, faces, names are very - its ’ just one of 

s. 

rlslface,butt !I enamersIm ’ not a great name person. I remember the 

116i Q 

[:,7! A 

You would recognize his face then? 

Well, Id ’ have - 

[ 1 s 1 some pictures. I mean, its real 

- l%\:“z?~:,“t:,“~~~hl~~s 

a thin 

I 191 aaain. the faces, but names 

of where I,-- 

izojofpeople, real1 . 

121: Q 

122 *ont ’ you? 

\oull ’ c&c&iy ‘ rerriemberMr. ’ Wisenberg. though, 

(231 A Oh. yeah, yeah. 

c241 Q Okay. They all do. 

l?S! 

-___-_I__ 

OlCStan 
BY MR. WISENBERG: 

Q I want to go back to a questron Mr. Bittman asked 

I and let me re-ask it. 

Page 62 Page 65 

::. agen!s who nave talked to you about therr knowledge of Ms 

.: Lewmkv? 

:.Mr. 

The statement that you told us about that 

.- Byrne, Gary Byrne told 

: :you recall talkin 

{ou he made to Evelyn Lieberman - 

about that 

A ?es. 

Q Mr. Bittman asked you, how typical wasthat? I 

+.mean, in your expertence - lets ’ just talk about the Clinton 

I::: -Wblte House. Are 

-1: made ‘ to Evelyn Lre 4 

ou aware of any other type statement bern 

erman by uniformed or plarnclothes Secre ? 

1:. Service? 

._ A No. 

-1 Q 

: f it? 

Meantng no one told you, or you havent ’ heard of 

.i A I havent ’ heard of any statement by an bod 

._. Q Okay. Does ri strike ou that that wou Y d no r be a 

: usual type statement. a usual type s r atement that a Secret 

: I i Service - he was umformed. correct? 

.-.. A Thats ’ correct. 

. ..^. 

.-- Q 

A 

Was he your supervisor? 

.--. 

Q 

No, he was just an off&r like myself. 

Okay. That a uniformed officer would - is that 

:~~:typical of a statement a uniformed officer would make to 

:I s:somebody in Ms. Liebermans ’ position? 

Le.’ - A Thats ’ correct. 

: ‘

i 5.stewards.7 

0 Did you develop any relationship with any of the 

I : . 

I-- 

. . . :A. 

A Both Nelvis and Glenn, 

YI 

es 

0 zf;;;sfnends with bot of them? 

A 

i ::would be a work friend 

- work frrends, okay’ It basically 

::;-Speakng football wrth 2 

pe relationship that we had. 

lenn. you know, we talked football 

;:: :and baseball. et cetera. He was a Colorado RockreslDenver 

: :.--Broncos fan 

.- Nervis was - more or less was not a sports-mrnded 

i:r‘ 

r 

rson. He was more into the nrce ties, et cetera, and stuff 

; ~5‘ Ike that w$d atways talk about. 

:z:. Speaking of work friends, is that how you would 

[ 1: ~descnbe Ms. lewrnsky, as a work fnend? 

i-2: A Actually, I didnt ’ work with her. It was a - more 

[:3;of a Hi. ‘ how are you doing” type thing. You really couldnt ’

I 2 1: say we were friends. I mean, rt was - it was just she spoke 

[,-s:to me and I spoke to her. 

Page 63 Page 66 

. A Well. again, you have to know Officer Byrne to know 

iliwhere hes ’ coming from. Hes ’ very conscrous about the .ob. 

: :: He takes the job in full - he wants to do a good job. An d 

.::apparently this had bothered him, her showing up there quite 

il: Q 

12 : grounds? 

Did you ever see her outside of the White House 

[3: 

!a: $ 

No sir. 

I i.oroundso 

Did you ever talk to her outside of the White House 

1186 

Lewis Fox. 2117198 XMAXllli 

; frequently. 

Q Were 

jall, I mean, uniforme cy 

ou all under any kind of-when I say you 

or nonunifo~ed Secret Servtce - 

; under any kind of implicit or explicit instructions from 

.anybody to notify senior staff when incidents like this 

occurred? ‘

A No. 

Q That is to say, when I sa 

hanaino around too close to the Oval 0 x 

incidents, people 

ice. 

:’ --A No 

I’ 0 All right. Mr. Bittman had asked you some 

. ‘ : : questions about Secret Servrce. Doesnt ’ Secret Service - 

.I’ jand Im ’ not necessarily talkrng about uniformed -- dont ’ they 

: 2 : investigate some counterfenrng offenses? 

.-s, A Thats ’ correct. 

._.. Q And also dont ’ the have jurisdiction to 

i! f : investigate some credit card frau d type cases? 

. . 

.--_ A Thats ’ correct 

.-- Q Oka Thats ’ all I have right now. 

. . . . MR. BIT-&MAN: Mr. Fox if 

:! ;. Im ’ going to ask the grand jurors if they 

ou would stand outside, 

t; ave any questions 

Page 64 

:::foryou. _^, 

.-. rtness excused Witness recalled. 

2‘ ’ Y HE FOREPERSON: 

;&hat youre ’ still under oath. 

Mr. Fox, Id ’ / Ike to remind you 

:;; THE WITNESS: 

Yes maam ’ I understand. 

C; ‘ ’ ’ 

i- 4s 

- BY MR. 6IlTMAN: ’ 

._. Q 

: : : referred to 

Have you ever heard, Mr. Fox, Ms. Lewinsky being 

as The ‘ S alkef? 

A No. 

Q Have you ever heard any rumors, other than from 

::: :felow uniformed officers, about Ms. Lewinsky hanging around 

::::the Oval Office? 

. ‘ 2‘ 

.-.. A No. 

::i: 0 The only &le that ever told you about that were 

: 1 J ; uniformed officers? 

. . _. 

.-c. A Thats ’ correct. 

-y-. Q How much did you associate with agents from the 

f i 3 i Secret Service? 

.. i’ .V+: * R Theyre ’ in their own little group, and the onv way 

i! 3 j you would ever see them is maybe if you were at a restaurant 

::: :or at the Outback or, say, one of the bars downtown, you 

::::might run into - might run into somebody on the detail or 

::: Istop by for a drink or somng like that. Never really 

: : ; : assocrated with an . 

.-:. 

_--. Q 

- anybod 

In tie last mon Y h have you talked to any @her 

[ i : : staffer. 

ill: It was a young congressional staff member. 

t:3: z A young con ressional staff member. Is that a 

i 1:. term. congressional staffer, P hat IS commonly used in the 

[:::Whtie House for someone who works in the Qffice of 

! I 6 : Legrslative Affair9 

A I would say that it would be - that they would be 

i 1; i referred to as a congressronal staff, East Wing congressronal 

i : 9: staff. okay7 

i?CT: 

[r:: 1 West Wrn 

Theres ’ East Wing congressional staff. and in the 

theres ’ the congressional staff over there, the big 

:~:boys. the a eavy hitters. 

Q So thats ’ a term - that is, congressional staff 

i; i j con ressronal staffer is a term common1 used for people who 

;25.wo R rn the White House who work in ma Ii ers related to 

_ ,- -~~~..-~~ ---_. _- -. ~~ _~ ~_ 

Page 67 

i I J Capitol Hill? 

[2: A Thats ’ correct. 

0 

i: iafter the president came out and asked 

Okay. You also said that o;ggee a description 

a io 

[ 5 j congressronal staffer that he was expecting. When the 

I 6 j presldent reentered the Oval Office and shut the door, that 

[: j you then made a comment - actually, the agent came up to you 

r 3 1 and satd. What ‘ is he talking about? and then you gave some 

c 3 1 descnptron to the agent. 

To the best of your recollection, tell us what you 

I i Y ! totd the agent. 

I said Well shes ’ dark-haired.” I said - and I 

[ :?! kind of we:t - I kindof ’ went like this (indicating), and 

rla!then I said - 

115: Q 

A 

Indicating for the - 

Indicating a full-figured breast. I mean 

! if i basically you know. And then I said “And it widens but at 

i I s j the hips w&h baby fat.” That was - that was the statement 

:19!1 made. 

0 And you previously indicated that she had dark 

i:? j hair. Any other description that you remember? 

(22: A That was ust ‘ basically how I described her to him. 

123: MR. BITTMA d : 

i 2 .I : Go ahead. 

Sol, do you have any other questtons? 

125: BY MR. WISENBERG: 

- -~~~~ __. 

Page 62 to Page 67 
1187 

BSA Lewis Fox, 2l17/98 

Page 71 

XMAX,:2’ 

Page 68 

i : ;, Monica wig voF$d Net the steward Net did he ever drscuss 

..I 

. . 

I -3 A ’ Yes. 

::; Q Tell us what he told you about Monrca. 

.:. A Well, t was workrng over one ni 

i 2 ;- it was a Monday night 

ht. 

i! 

It had to be 

So I came up to the 

: 7 j Nel at thus time was krnd of like - I could see 

6 post, and 

he was 

: 1: lsavs. “I thouaht so.” i;?; ’ And I didnt ’ pry anymore. That was - you know, l 

! i 9; could see that he was upset. 

!2Gj Q Okay. Drd he ever have any other discussrons 

[ 11 I 1 you about Monica? 

[2Zl A Well, he had told me that she had called him in 

[ 2: 1 pantry, you know, a few times. 

I?41 Q 

!ZCj A 

$ he tell you what she had called him about? 

with 

the 

Page 69 

(1; Q 

i 2 1 Monica? 

Any other conversations you remember with Nel about 

i31 A 

Q 

No, just those. 

You said that Nel liked ties, if Im ’ not mistaken. 

i :iDo you recall if he ever told you that Monica had given him 

161ties. 

171 A No. 

(3; Q 

I 4 1 ever aiven 

Do you remember him telling you that Monica had 

,:q: - 

him oifts? 

, *i A No. :..I L _- Q Do you - and stag me if Im ’ breachin 

; : 2 : agreement youve ’ reached with t e Secret Servce. 

;r~y 

; 13: t 

: ;; 1 t x 8 

ptcall if a person - lets say youre ’ at your 

8 , 

ost at 

e 11: 0 door, and a person were to come rn -P o the Oval 

r :j:Office, whether or not the presidents ’ there, would you write 

I : 6: that down anywhere? 

r.-, A The only people that would be - that we would log 

1 I?:in a book would be the maintenance workers and the people 

1: 5 i that would come over - like Park Service employees who would 

! 2 r: 1 water the flowers. a radio address, the people that came over 

[ :: 1: to the Oval Office and removed the furniture, the White House 

! 2~; military peo le who would go in and make a phone check. On 

: zx~every shift t R ey would be logged in into that book ::a, It would only be people that were working - I 

;:::mean, going in, as what I sard. to water the plants, change 

Page 70 

1s: Q 

19: need to lo 

Okay. But lets ’ say in that situation you wouldnt ’

%, 

them in. Is that what youre ’ saying? 

ZCJ 7.. -11 Q 

Thats ’ correct. I wouldnt ’ have to log them in. 

You would not have to. 

111 

..-. A No. 

tiR. %EiuBERG: 

MR. BINHAK: 

I think thats ’ all Ive ’ got 

t just have a short question. 

.- BY MR. BINHAK. 

;L Cl Drd you know whe!her Nei and -- obvrously. Ne and 

: 3 Montca knew each other because Nel referred to her by name :; 

: vou. correct? 

.; ’ 

.- 

.z ‘

- 

._ 

Is -conversatr& 

I.“, Ical,) 

ou know 

A Thats ’ c- orren --- -. 

F Do you I..._.. knnw ,._ hnw Net knew Monrca7 

kl*+ *-“*I, no. I mean .__... ,-. II5! rn general 

he wou!d tell me thaf-- again, after 

alled aacx to the pantry or the 

:ed that 

! 2 she left there 3 t at she r$ 

; : : -other - as I Indicated, that he asked me if Id ’ work 

i:: ,weekend, and I told him 

:::.been there, and I said, 

es. He wanted to know if Monrca 

&elI. I heard she was here,” and he 

ha; 

: : 3: said, Well. ‘ I thought so.” 

[L:- And. you know. I didnt ’ push hrm anymore because at 

; : 5 : that point I &uld see he was upset 

“E Q When you said that she called the pantry, did sre 

: l-come ‘ in person or did she call bv Dhone? 

[if‘ .A Called b 

(13 Q 

r 2 2. Monica? 

Do you i 

phone.’ 

now how often Nel would have contaa wrth 

;-> : 

>..I, A No, thats ’ - I have no idea. 

(2:: 

1::: 

Q 

A 

Do you know any reason wh Monica would know Ne17 

(24 jknow - 

Only because hes ’ the press CT ents ’ valet or, you 

[Z!S: Q Was tt common for interns to know the presiden:s ‘

I : :valet or stewards? 

Page 72 

an intern at -you know 

blue pass with a blackWas it common forjunior level staff members wth 

[ 6: blue passes to know the presidents stewards or valets? 

A 

ii :and tried to get a relationship gom 

Well. probably - again, that if you spoke to them 

: syes. they would. you know, say. 8h. ‘ I know that person: 

or a friendship going 

;:z:or - or whatever. 

Lil: Q Dg many junior level staff members take the time to 

;;;ispeak to the presrdent s valets and stewards? 

A Well. again, when the presidents ’ there, theyre ’ :n 

::~:this walkway, Walkway 1 area, pantry area, and it would be 

i 1:: nothing un~mmon for some staff members or anybody, whether 

[Ii:- probably to come down and ask for, “Hey, can you 

I I-: wp of ice,” or. “Can you get me some presrdential M 

et me a 

r:z.stuff like that, because Nel had access to those. 

8 MS,” 

[!? Q Now. 

I-:’ the Congresslonai A 4, 

ou said that Momca Lewrnsky was workng In 

arrs Office. and I think you sard she 

I 2 1. was in the East Wina? :-. 

_--_ A That% correct r-2. L..d Q So she wasnt ’ stationed in the West Wing of the 

r:::White House, correct? 

t::: A Thats ’ correct 

Page 73 

I: ’

[ 1 :get a 

Q So when you sa that people who would be around to 

I? 

lass of ice or a cup of co f; 

rr!:presl 

ee or maybe some 

enhal M&MS. l guess youre ’ presupposing someone that 

I i:would have a Certain amount of contact with those peo 

: 5: therefore a cenaln amount of access to that portion of he 

; c;Whtte House; IS that correct? 

P 

le. and 

A Or to that area. yes. It would not necessarily - 

12 jit could have been, you know, anybody that would walk in, a 

:g:staff member or a person working there would say, “Can you 

[ ;c;get me some presidential M&MS, you know. 

I::! Q So does that assume - well, would it be common for 

! x? someone who worked in the East Wrn 

spoke to her. she always spoke back, you know. 

Ii?: I never really put her in the catego of whether 

rls:she was - not unfriendly, okay? She was a r nendly type 

rx:person. 

ill. BY MR. BITTMAN: 

12:: Q Mr. Fox, have you ever been in the study? 

i?i‘’ A Yes _-. 

Q 

A 

How many times? 

Enough to know what was in there. 

- olcstan 
Lewis Fox, 2117198 XMAXl13) 

Page 77 

BSA 

1188 

Page 74 

been in the study during President 

14‘ Q 

.:. A 

What occasions would you go to the study? 

Just a lot of times ust ‘ to -just, you know - a 

r;;lot of times the lights would be le A 

?‘know ‘

on, et cetera, and. you 

i 3: aroun 2 

oud ’ come on and you - and you just like to walk 

when you maybe go on dut 

s.make ‘ sure that the rv 

and youd ’ walk in just to 

: : 3: thmgs liite that, km 2 

ictures were s 111 on the walls and 

of telling yourself -- make sure 

: 1: Ieverything was in the proper 

I :z !general secunt check of tha P 

lace and, you know, just a 

113’ Q 

: : 4 : study” 

bid you ever look under the presidents ’ desk in the 

r-c> .-_I> A No. 

.,j‘ ‘ 

.- 0 Oka 

..7’ 

.- MR. WISENBERG: I. ,’ 

.--/ BY MR. WISENBERG: 

I have a few questtons. 

:I?] 0 You mentioned when you were talking about Monicas ’

: 2 3 1 calls to Nel. I think you mentioned the words, “She would 

.2: .call after she left there.” I iust want to make sure what 

i3ziyou meant. 

123; Do you mean like after she left the White House? 

[?4! A After she left the White House and went to the 

:?s!Pentagon, yes. 

A Yes.%r. 

._. 

.--, Q You would do that when the president was not there? .T^, 

.--. A Yeah, just generally youd ’ take over the 

22 1 assignment. Like of a morning, your mornin 

Mere there like on the weekend, youd ’ take t ?I 

shift, if you 

at over 

Q Okay. Would you ever go into the study if you knew 

Page 76 

ie prestdent was in the Oval Office area? 

A Would not even think about it. 

,; Q Okay. Because? 

[4] A Well. if I would have went in there, I would have 

rjlprobably been transferred immediately. 

.~~ ioj Q All ri ht. 

[7] A 

Q 

I wou 9 d have been transferred,out of the West Wing. 

:8i 

A 

Okay. So that would be a major no-no. 

F51 

Q 

Oh, d would be a major no-n?, yes. 

Okay. What would you consider to be. based on your 

’ 1: t knowledge, your experience in Secret Service, absoiuteiy the 

.: 2 I most private - the private room in the entire West Wing In 

13 ‘ 1 terms of the sanct’ 

$ 

of the presidents ’ privacy? 

141 A Wel. from orevious - aaain. from orevious 

ilsjpresidents- ’ 

“. . 

(161 Q Just from President Clinton. 

Cl71 A 

: I 8 1 study. 

Oh, okay. President Clinton, I would say the 

:I91 Q Mr. Bittman asked you things you had heard from 

rzolother Secret Service 

!2 I 1 and you told us abou pe 

rsonnel, and I asked you about Nel, 

Nel. 

l-1 .--‘ Did any other people in the White House - stewards 

[23!-- 

I41 ’

you kn? yo;ltt;troned ’ the other steward, Glenn. 

r-5; .- Q Did anybody else talk to you about Monica? 

A No. 

MR WISENBERG. Thats ’ all Ive ’ got. 

MR BITTMAN. Mr Fox, youre ’ excused. Thank 

at 12:OO noon. the taktng of the 

-- 

YOU 

OlCStafT Pi@ 74 to Page 77 
1189 

E 

i 

J 

\ ‘
1190 
1191 

OK-302 (Rev. S-:9-94) 

- 1 - 

OFFICE OF THE INDEPENDENT COUNSEL 

Date of transcription 2/23/98 

On below date, investigating Agents identified 

themselves, stated the purpose for the interview and interviewed 

M. KATHERINE FRIEDRICH at the Office of the Independent Counsel, 

1001 Pennsylvania Avenue, N.W., Suite 490 North, Washington, D.C. 

20004. FRIEDRICH provided the following: 

FRIEDRICH, date of birth January 1, 1968, place of 

birth Worcester, Massachusetts, 

-, currently resides at 

Q@--, home tele 

FRIEDRICH is the Special Assistant 

Security Advisor. 

to the Deputy National 

Her office is located in the West Wing of the 

White House, First Floor, telephone numberFRIEDRICH has been employed at the White House since 

July of 1992, when she worked in the Office of Administration 

(OA), 

Council 

FRIEDRICH left OA and came over to the National Security 

in June of 1995. 

As Special Assistant to the Deputy National Security 

Advisor (NSA), FRIEDRICH's duties and responsibilities include 

scheduling for the Deputy, 

intelligence, 

JIM STEINBERG, giving him up-to-date 

FRIEDRICH also 

and keeping him aware of late-breaking matters. 

travels with the President on all international 

trips. 

FRIEDRICH met MONICA LEWINSKY at a Christmas party held 

at LINDA TRIPP's home on December 20, 1997. 

for a short period of time, 

LEWINSKY only stayed 

LEWINSKY very much. 

and FRIEDRICH did not speak to 

FRIEDRICH described the party as small, and 

could only recall that aside from LEWINSKY and TRIPP, a LINDSAY 

Last Name Unknown from the Pentagon was present. 

FRIEDRICH has been friends with LINDA TRIPP since 1994, 

when they were both employed at the White House. FRIEDRICH has 

socialized with TRIPP often, visiting TRIPP at TRIPP's home on 

numerous occasions. 

In July of 1997, TRIPP told FRIEDRICH that LEWINSKY had 

told TRIPP that LEWINSKY was having an affair with the President. 

FRIEDRICH believed this, as there was no reason to doubt it. 

Investigation on 2/20/98 at Washington, D.C. File # 29D-OIC-LR-35063 

Date dictated 2/23/98 
1192 

OIC-302a (Rev. 8-L9-94) 

29D-OIC-LR-35063 

Continuation of OK-302 of M. KATHERINE FRIEDRICH .On 2/20/98 ‘ .Page 2 

FRIEDRICH recalls speaking to TRIPP about this around the same 

time the KATHLEEN WILLEY story made news. 

TRIPP told FRIEDRICH that she was taping telephone 

conversations TRIPP had with LEWINSKY in November of 1997. TRIPP 

told FRIEDRICH that TRIPP felt as though she would be the only 

person telling the truth, and TRIPP had to preserve the LEWINSKY 

story. TRIPP felt that TRIPP would be questioned about her 

conversations with LEWINSKY at a later time. TRIPP also told 

FRIEDRICH that she taped the telephone conversations because 

TRIPP"felt that LEWINSKY could not tell the truth if she were 

deposed. TRIPP also felt that she had been treated badly after 

the WILLEY matter, and felt that no one would believe her unless 

she had hard evidence. FRIEDRICH advised TRIPP to bring all the 

tapes to TRIPP's lawyer's (KIFU3Y BEHRE) office for safekeeping. 

FRIEDRICH believed that there were ten or eleven tapes in all. 

FRIEDRICH heard a portion of one tape that TRIPP played 

for her. This tape included a portion in which TRIPP yelled at 

her (TRIPP's) daughter. TRIPP felt concerned that this was on a 

-tape that also contained conversations with LEWINSKY. FRIEDRICH 

advised TRIPP not to erase the tape, but to turn it over to 

TRIPP's lawyer. FRIEDRICH believed TRIPP did this. FRIEDRICH 

did not listen to or see other tapes. FRIEDRICH did not see the 

equipment TRIPP used to tape the telephone calls. 

FRIEDRICH advised that TRIPP had a deposition set with 

PAULA JONES' lawyers in January. TRIPP felt she had no time to 

attend. 
1193 

Olf-3’ (Rev 8-19-94) 

- I ’ 

OFFICEOFTHE IMDEPENDENTCOUNSEL 

Date of transcr:ptm! 07/20/98 

KATE FRIEDRICH, previously identified and previously 

apprised of the official identity of the interviewing Agent, was 

interviewed at the Office of the Independent Counsel (OIC), I.001 

Pennsylvania Avenue, NW, Washington, DC, 20004. FRIEDRICH 

provided the following information: 

FRIEDRICH works at the National Security Counsel (NSC) 

and has known LINDA TRIPP since 1994. The two met at the White 

House. 

January of 1998 was the first time FRIEDRICH heard the 

name LEWINSKY. In August of 1997, FRIEDRICH was told by TRIPP 

about a girl who TRIPP was friends with, who was having a sexual 

relationship with President WILLIAM JEFFERSON CLINTON. 

FRIEDRICH never heard about LEWINSKY wanting to get a 

job in the White House. FRIEDRICH never heard LEWINSKY's name 

mentioned at the NSC and, therefore, never mentioned anything 

about that to TRIPP. FRIEDRICH never heard about the 

circumstances surrounding LEWINSKY's leaving employment at the 

White House. 

FRIEDRICH did not want to talk about the relationship 

between l'MONICAV and CLINTON. FRIEDRICH listened to TRIPP, but. 

discouraged that subject matter when it arose. 

FRIEDRICH did fax a job posting to TRIPP, announcing a 

vacancy in SANDY BERGER's office. FRIEDRICH told TRIPP to call 

MARSHA DIMMEL, who handled job vacancies in the NSC, FRIEDRICH 

told DIMMEL that someone may be calling her. FRIEDRICH did not 

know who it was, but told DIMMEL that a friend of FRIEDRICH's, 

whom FRIEDRICH felt was bright, had recommended this person, who 

also worked at the Pentagon. FRIEDRICH told DIMMEL that her 

friend said her co-worker was "very good," and they were willing 

to work the difficult hours required by the job. FRIEDRICH has 

no idea if TRIPP called DIMMEL. 

FRIEDRICH does not know anyone else who knew LEWINSKY. 

FRIEDRICH did not spend a lot of time discussing LEWINSKY with 

TRIPP. When FRIEDRICH met LEWINSKY at TRIPP's Christmas party in 

December of 1997, LEWINSKY said she had some interviews in New 

invcstrgauon on 07/17/98 at Washington, DC File # 29D-OIC-LR-35063 
1194 

OIC-3OZa (Rev. 8-19-94) 

29D-OIC-LR-35063 

Conunuadon of OIC-302 of KATE FRIEDRICH .On 07/17/98 ,Page 2 

York. 

FRIEDRICH advised that TRIPP was very upset with BOB 

BENNETT'S comments about TRIPP. FRIEDRICH said she would not 

have spoken to a reporter. $RIPP said that ISIKOFF was harassing 

her, so she felt she had no choice. TRIPP made the tapes because 

she was trying to cover for herself. TRIPP felt she was going to 

be called by the PAULA JONES' attorneys. 
1195 

OK-302 IRS 8-19-94) 

-lOFFICE OF THE INDEPENDENT COUNSEL 

Date of ttanscnpuon 04/07/98 

ANDREW (NO MIDDLE NAME) FRIENDLY, white male, date of 

birth- place of birth eesS;;ial 

Security Account Number--+ 

the identity of the interviewing Agents and the purpose of the 

interview. FRIENDLY was interviewed in the presence of his 

attorney, DAVID WILSON. FRIENDLY provided the following: 

FRIENDLY was hired in February of 1992 as a consultant 

for the CLINTON/GORE Presidential Campaign. FRIENDLY did advance 

work until the 1992 Presidential Election, and then was part of 

the transition team, based in Little Rock, where FRIENDLY also 

did advance work. 

FRIENDLY served as President CLINTON's Personal Aide 

from January 21, 1993 until the end of October 1994. As Personal 

Aide, FRIENDLY was responsible for annotating the President's 

daily schedule, keeping the President on schedule, and traveling 

with the President. 

FRIENDLY advised that every workday morning he received 

the President's schedule from the Scheduling Office. FRIENDLY 

would work from this document and annotate the schedule as the 

day went on. FRIENDLY explained that meetings would often be 

changed and rescheduled throughout the day. FRIENDLY would mark 

the schedule to reflect any changes he was aware of. FRIENDLY 

would also note the names of those who met with the President. 

Due to the large size of some meetings, FRIENDLY would be unable 

to note all participants at some meetings. 

FRIENDLY advised that every afternoon two to four hours 

of “phone and office time" would be set aside for the President. 

FRIENDLY would move from his desk outside of the Oval Office to 

another desk he had down the hall. FRIENDLY did this so he could 

catch up on his paper work. FRIENDLY stated that if the 

President had visitors during this time, FRIENDLY would not be 

able to annotate the President's schedule to reflect the 

unscheduled meetings. Every week--to ten days, FRIENDLY would 

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by Date dictated 04/07/98 
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Continuation of OK-302 of ANDREW (NO MIDDLE NAME) FRIENDLY .On 04/06/98 . Page 2 

forward the annotated schedules to ELLEN MCCATHERAN, the White 

House Diarist, by the White House mail. FRIENDLY advised that 

FRIENDLY did not go with the President, to the White House 

residence after the work day. 

FRIENDLY stated that he was responsible for keeping the 

President on schedule. If a meeting ran late, FRIENDLY would 

remind the President of the President's next engagement. 

FRIENDLY advised he would knock on the door of the meeting room 

if necessary to remind the President of the President's schedule. 

FRIENDLY, as Personal Aide, would also travel with the 

President. FRIENDLY was responsible for the President's personal 

effects, including the President's briefcase. Before 

Presidential travel, FRIENDLY would meet with BETTY CURRIE, the 

President's Secretary. CURRIE would give FRIENDLY a list of the 

telephone calls that the President should make. FRIENDLY would 

keep track of the telephone calls the President made by marking 

this telephone log. FRIENDLY .would, at times, speak 

telephonically with CUFXIE, and CURRIE would inform FRIENDLY of 

names to add to the telephone log. FRIENDLY would return this 

telephone log to CURRIE at the end of a trip. FRIENDLY would 

also keep an annotated daily schedule during Presidential trips. 

FRIENDLY was responsible for keeping track of gifts the 

President received while the President traveled. FRIENDLY would 

fill out a standard gift form, and then forward both the form and 

the gift to the White House Gift Unit upon his return to the 

White House. _ 

FRIENDLY advised that .he could recall meeting KATHLEEN 

WILLEY on one occasion. This meeting occurred sometime in 1993, 

outside of the Oval Office. FRIENDLY stated that he observed 

WILLEY to be'sad, downcast, and had watery eyes as if she had 

been crying. WILLEY had a meeting with the President in the Oval 

Office. FRIENDLY advised that he believes he learned at that 

time that WILLEY was upset because her husband had killed 

himself. FRIENDLY stated that either KELLY CRAWFORD, BETTY 

CURRIE, or NANCY HERNREICH probably told that to him at the time. 

FRIENDLY could not recall WILLEY leaving the Oval Office, or if 

he had to knock on the door to remind the President of the 

President's schedule. FRIENDLY could not recall when, in 1993, 
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Continuation of OIC-302 of ANDREW (NO MIDDLE NAME: FRIENDLY .On 04/06/98 .Pa_ne 3 

this meeting occurred, and he could not recall annotating the 

President's schedule to reflect the meeting with WILLEY. 

FRIENDLY never saw WILLEY in the Oval Office again. 

FRIENDLY advised that he was aware that WILLEY was a 

volunteer in the White House Social Office. FRIENDLY saw WILLEY 

at a couple of large White House events. 

FRIENDLY stated he did not know, and had never met 

MONICA LEWINSKY. 

FRIENDLY advised that he has not spoken with anyone in 

the White House Counsel's Office concerning WILLEY. FRIENDLY has 

not spoken with BOB BENNETT or DAVID KENDALL about WILLEY. 

ELLY CRAWFORD about WILLEY. - 

OK-301 (Rev. S-19-94) 

1199 

- 1 - 

OFFICE OF THE INDEPENDENT COUNSEL 

Date of nansctiption 04/24/98 

MATTHEW FRITSCH, Lieutenant, United States Secret 

Service (USSS), Uniformed Division, was interviewed at the Office 

of the Independent Counsel (OIC), 1001 Pennsylvania Avenue, 

Washington, DC, 20004. Present for the interview were Associate 

Independent Counsel (AIC) MARY ANNE WIRTH, AIC MICHAEL TRAVERS 

and Department of Justice (DOJ) attorneys GARY GRINDLER and 

JONATHAN SCHWARTZ. FRITSCH was interviewed under the terms of an 

agreement reached between the OIC and the DOJ.. After being 

apprised of the official identities of the interviewers and the 

nature of the interview, 

information: 

FRITSCH provided the following 

FRITSCH has been employed by the USSS since July of 

1976. FRITSCH has had a number of assignments at the White 

House, including one during the period from April of 1994 until 

August of 1996. FRITSCH worked in the Special Operations 

Division (SOD), which handled tours and special events handled at 

the White House. When FRITSCH worked in the SOD, he interacted 

with the White House Social Office and the White House Visitors 

section. 

FRITSCH had an office in the Old Executive Office 

Building (OEOB), 

of the-East Wing. 

but spent most of his time in the ground floor 

FRITSCH first met MONICA LEWINSKY when she started 

*<-:rking in the Office of Legislative Affairs (OLA). FRITSCH saw 

::WINSKY a couple of times a week during this period. FRITSCH 

.rescribed his relationship with LEWINSKY as being friendly. 

FRITSCH described LEWINSKY as friendly and flirtatious. FRITSCH 

advised he and LEWINSKY spoke only about generalities and never 

about President WILLIAM JEFFERSON CLINTON. 

FRITSCH advised that one of the Uniformed Division 

officers who was stationed at post 

may have told FRITSCH that LEWINSKY 

and JOCELYN JOLLEY had been transferred out of the White House. 

FRITSCH believes the Uniformed Division officer who told FRITSCH 

this was FREMON MYLES. FRITSCH heard that LEWINSKY was 

transferred to the Department of Defense. FRITSCH did not know 

where JOLLEY was transferred. FRITSCH knew JOLLEY only to see 

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Continuation of OIC-302 of MATTHEW FRITSCH son 04/22/98 .page 2 

her. FRITSCH has not spoken to LEWINSKY since she left employ at 

the White House. FRITSCH never saw LEWINSKY outside the White 

Hause. 

Prior to LEWINSKY leaving employ at the White House, 

FRITSCH heard rumors from MYLES that LEWINSKY had "something 

going" with CLINTON. MYLES told FRITSCH that one of the White 

House cleaning people was told by one of the White House stewards 

that one of the stewards had cleaned up after CLINTON and 

LEWINSKY had been in the Oval Office. FRITSCH understood MYLES 

to mean the stewards saw a lipstick-stained tissue in an Oval 

Office garbage can. 

LEWINSKY gave FRITSCH a Christmas card in either 1994 

or 1995 and at the time she gave FRITSCH the card, she also 

hugged him. 

FRITSCH advised he did not speak to anyone outside the 

USSS about the rumors about LEWINSKY and CLINTON. FRITSCH 

advised his supervisor in the SOD was Lieutenant BRYANT WITHROW. 

FRITSCH never discussed LEWINSKY with WITHROW. 

FRITSCH knows JAMIE BETH SCHWARTZ and is friendly with 

her. FRITSCH gave home on one occasion. 

FRITSCH never heard a rumor about CLINTON and LEWINSKY 

being caught in a compromising position. 

FRITSCH played on a USSS softball team. FRITSCH has 

been to a bar called the "Bottom Line." FRITSCH does not recall 

seeing SCHWARTZ at the "Bottom Line." FRITSCH does not recall 

speaking about LEWINSKY and CLINTON at the "Bottom Line." 

FRITSCH knows a couple of women named NICOLE. FRITSCH does not 

know the name NICOLE MAFFEO. 

FRITSCH does no; know the name BAYANI NELVIS or GLEN 

MAE&S. 

After January 22, 1998, FRITSCH heard rumors from other 

USSS employees about LEWINSKY and CLINTON being caught in the 

White House theater. FRITSCH discounted the rumors because the 

doors to the theater are locked and if the President was in the 

theater, the doors to the theater would be posted by USSS Agents. 

- 

FRITSCH drew the attached diagram which shows the 

layuot of the White House theater area. m-1 
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Continuation of OIC-302 of MATTHEW FRITSCH .On 04/22/98 ,Page 3 

Agent's notes of this interview. 

FRITSCH advised that TOM OWENS, a USSS Uniformed 

Division officer, works for FRITSCH. FRITSCH is aware that OWENS 

has been interviewed by the OIC about the LEWINSKY matter. OWENS 

said he was asked about CLINTON calling OWENS and discussing 

OWENS allowing LEWINSKY into the White House. OWENS said he 

never got that call. 

Another rumor FRITSCH heard about LEWINSKY was that she 

would ask Uniformed Division officers about the President's 

whereabouts. FRITSCH advised BRIAN HENDERSON, a Uniformed 

Division officer, told FRITSCH that LEWINSKY would listen to the 

Uniformed Division officers' radios to determine the President's 

whereabouts. HENDERSON told FRITSCH that LEWINSKY was a little 

"wacky." 

GARY BYRNE, a USSS Uniformed Officer, works with 

FRITSCH at the USSS training center in Beltsville, Maryland. 

BYRNE is upset about stories he has heard about BYRNE going to 

EVELYN LIEBERMAN about LEWINSKY and getting LEWINSKY fired. 

BYRNE told FRITSCH that BYRNE did not discuss LEWINSKY with 

LIEBERMAN. 

FRITSCH advised that LIEBERMAN described herself as a 

"bulldog." 

FRITSCH advised that another rumor he heard was that 

LEWINSKY showed up at the Northwest gate and became very upset 

when she could not get in to see the President. FRITSCH heard 

this rumor from Seargeant RON PARTHEMOR. 
1202